- WHO ARE WE?
1.1 Your personal data are processed on the basis of applicable data protection legislation by LifeStyles Healthcare Pte. Ltd. of 30 Cecil Street, #19-08 Prudential Tower, Singapore 049712 (hereinafter: “LifeStyles”, “we”, “us”, “our”). You can contact us via e-mail at firstname.lastname@example.org.
- WHAT ARE COOKIES AND SOCIAL MEDIA PLUGINS?
2.1 Cookies are small text files which are stored on your device’s hard drive which contain certain information or personal data.
2.2 Social media plugins are small pieces of software developed and provided by social media service providers (such as Facebook), which allow us to integrate social media on our Website.
2.3 Similar technologies are small pieces of software or invisible images (such as the Facebook Pixel) developed and provided by several service providers, which allows us, for example, to track conversions or to better target our promotional campaigns.
- WHICH COOKIES, SOCIAL MEDIA PLUGINS AND SIMILAR TECHNOLOGIES DO WE USE?
3.2 We may use the following type of cookies:
– Strictly necessary cookies which are required for the operation of our Website;
– Functional cookies which are used to recognise you when you return to our Website;
– Performance-enhancing cookies which are used to recognise and count the number of visitors to our Website and analyse how visitors move around our Website;
– Advertising cookies which are used to record your visit to our Website, the pages you have visited and the links you have followed.
3.3 Our Website uses Google Analytics. This web analytics service, provided by Google Inc., uses analytical cookies. This service helps us to collect and analyse visitor information (such as browser usage, new visitor numbers, response to marketing activity and browsing times) to improve our Website and your experience, and to make our marketing campaigns relevant.
The information collected through Google Analytics cookies about your use of our Website is sent to and stored by Google, together with your IP address. Google may, for example, use this information for the following purposes:
- Provide advertising activity reports to advertisers and websites that host the advertising and ensure that those website publishers are paid for;
- Detect and combat fraud and other security risks to protect users and partners;
- Fulfil its legal obligations;
- Improve its materials;
- Help Website and app owners using Google Analytics to understand how visitors interact with their sites or apps.
For all these activities with the exception of the last bullet point, Google acts as the data controller and the processing of the data it collects about your use of the Website takes place under its responsibility. Learn more about Google Analytics Cookie Usage on Websites.
However, you can control what information is sent to Google in the following ways:
- If you do not want Google Analytics to be used in your browser, you can install the Google Analytics Opt-out Browser Add-on. Learn more about Google Analytics and Privacy.
- If you are logged in to your Google Account, you can – depending on your account settings – view and edit certain data that Google collects from sites and apps you visit.
- The incognito mode in Chrome allows you to browse the Internet without having web pages and files recorded in your browser history. Cookies are deleted after you close all incognito windows and tabs. Your bookmarks and settings are saved until you delete them.
- Advertising settings allow you to manage which Google ads you see on the Internet. You can find out how ads are selected for you, unsubscribe from ads personalization, and block specific advertisers. Learn more about ads.
3.4 Our Website uses the Facebook Pixel. This is an invisible image that is included on the pages of our Website and that is stored on Facebook’s servers. Each time you open a page of our Website where this pixel has been recorded, this pixel is downloaded to your device from that Facebook server. The following data is provided to Facebook: your IP address and the specific characteristics of your device (e.g. type, operating system, specific software and hardware).
We only receive statistical information from Facebook itself and not your personal data.
If you do not wish to receive certain advertising, you can adjust your advertising preferences in your personalised Facebook page. Finally, via the settings of your mobile device, you can also indicate that the machine data cannot be communicated to third parties. Learn more about the Facebook Pixel.
3.5 In the table below, we provide you with an overview of the cookies and social media plugins that we use on our Website.
|NAME||TYPE||EXPLANATION / PURPOSE||STORAGE PERIOD|
|1.||_ga||Cookie (performance-enhancing)||Cookies provided by Google Analytics to help us measure how users interact with our Website’s content (see Article 3.3). Learn more about Google Analytics Cookie Usage on Websites.||2 years|
|2.||_gat||Cookie (performance-enhancing)||1 minute|
|3.||_gid||Cookie (performance-enhancing)||24 hours|
|4.||_utma||Cookie (performance-enhancing)||2 years from set/update|
|5.||_utmc||Cookie (performance-enhancing)||End of browser session|
|6.||_utmz||Cookie (performance-enhancing)||6 months from set/update|
|7.||Facebook Pixel||Similar technology||Technology provided by Facebook to measure the effectiveness of our advertising by understanding the actions users take on our Website (see Article 3.4). Learn more about Facebook Pixel.||N/A|
|8.||ad-id||Targeting/Advertising||Provided by amazon-adsystem.com for advertising purposes (tag present in GTM)|
|9.||ad-privacy||Targeting/Advertising||Provided by amazon-adsystem.com for advertising purposes (tag present in GTM)|
|10.||_cc_aud||Targeting/Advertising||Provided by crwdcntrl.net and is used for advertising purposes (tag present in GTM)||9 months|
|11.||_cc_cc||Targeting/Advertising||Provided by crwdcntrl.net and is used for advertising purposes (tag present in GTM)||9 months|
|12.||_cc_dc||Targeting/Advertising||Provided by crwdcntrl.net and is used for advertising purposes (tag present in GTM)||9 months|
|13.||_cc_domain||Targeting/Advertising||Provided by crwdcntrl.net and is used for advertising purposes (tag present in GTM)||9 months|
|14.||_cc_id||Targeting/Advertising||Provided by crwdcntrl.net and is used for advertising purposes (tag present in GTM)||9 months|
|15.||IDE||Targeting/Advertising||Doubleclick (tag present in GTM)||2 years|
|16.||_ga||Performance||Provided by Google Analytics (tag present in GTM)||2 years|
|17.||dnt||Targeting/Advertising||Provided by provenpixel.com (no related tag present in GTM)||5 years|
|18.||eu_cn||Targeting/Advertising||Provided by Twitter if the Twitter social plug-in on the website has been activated by the user. If you do not have a Twitter account or never accessed the Twitter.com website directly then Twitter will assign you a unique code to track your visit to the Twitter feed. (no related tag present in GTM)||1 year|
|19.||guest_id||Targeting/Advertising||Provided by Twitter (no related tag present in GTM)||2 years|
|20.||netpu||Targeting/Advertising||Provided by Twitter (no related tag present in GTM)||2 years|
|21.||personalization_id||Targeting/Advertising||Provided by Twitter (no related tag present in GTM)||2 years|
|22.||remember_checked_on||Functionality||Provided by Twitter (no related tag present in GTM)|
|23.||syndication_guest_id||Functionality||Provided by Twitter (no related tag present in GTM)||2 years|
|25.||twitter_ads_id||Functionality||Provided by Twitter (no related tag present in GTM)||2 years|
TO WHOM DO WE SEND YOUR PERSONAL DATA?
4.1 We may share your personal data with our related LifeStyles entities and we may also rely on third parties in order to process your personal data for the purposes outlined in Article 3 above, for example:
- To provide you our Website or webshop (such as a hosting provider); or
- To target our advertising (such as a marketing company); or
- To process your order (such as a transport company to deliver you the products); or
- To process your payment (such as a payment service provider or a credit checking agency).
These third parties are only allowed to process your personal data on our behalf and upon our explicit written instruction. We also warrant that all those third parties are selected with due care and are committed to observing the safety and integrity of your personal data.
4.2 We may be legally obliged to share your personal data with competent law enforcement agents or representatives, judicial authorities, governmental agencies or bodies, including competent data protection authorities, to comply with a legal obligation as set out in Article 3. above.
4.3 We do not send your personal data in an identifiable manner to any other third party than the ones mentioned in Articles 4.1 and 4.2 without your explicit consent to do so. However, we may send anonymised data to other organizations that may use those data for improving products and services as well as to tailor the marketing, displaying and selling of those products and services.
5. WHERE DO WE PROCESS YOUR PERSONAL DATA?
5.1 We process your personal data both within and outside the European Economic Area (EEA). In order to process your personal data for the purposes outlined in Article 3 above, we may also transfer your personal data to third parties who process on our behalf outside the EEA. Each entity outside the EEA that processes your personal data will be bound to observe adequate safeguards with regard to the processing of your personal data. Such safeguards may be the consequence of:
- The recipient country having legislation in place which may be considered equivalent to the protection offered within the EEA; or
- A contractual arrangement between us and that entity; or
- An approved certification mechanism, such as the EU-US Privacy Shield decision adopted by the European Commission on 12 July 2016.
5.2 We may transfer anonymised and/or aggregated data to organizations outside the EEA. Should such transfer take place, we will ensure that there are safeguards in place to ensure the safety and integrity of your data and all rights with respect to your personal data you might enjoy under applicable mandatory law.
6. WHAT QUALITY ASSURANCES DO WE COMPLY WITH?
6.1 We do our utmost best to process only those personal data which are necessary to achieve the purposes listed under Article 3. above.
6.2 Your personal data are only processed for as long as needed to achieve the purposes listed under Article Error! Reference source not found. above or up until such time where you withdraw your consent for processing them. Your withdrawal of consent may imply that you can no longer use the whole or part of our Website. We will de-identify your personal data when they are no longer necessary for the purposes outlined in Article Error! Reference source not found. above, unless there is:
– An overriding interest of LifeStyles, or any other third party, in keeping our personal data identifiable; or
– A legal or regulatory obligation or a judicial or administrative order that prevents us from de-identifying them.
6.3 You understand that an essential aspect of our marketing efforts pertains to making our marketing materials more relevant to you. We do this by customizing your unique profile based on relevant characteristics and then use this profile to provide you with communications, advertising, offerings, newsletters and other advertising about products and services that may interest you.
6.4 We will take appropriate technical and organizational measures to keep your personal data safe from unauthorised access or theft as well as accidental loss tampering or destruction. Access by our personnel or third parties’ personnel will only be on a need-to-know basis and be subject to confidentiality obligations. You understand, however, that safety and security are best efforts obligations which can never be guaranteed.
6.5 If you are registered to receive advertising, such as communications, advertising, offerings and newsletters, via e-mail or other person-to-person electronic communication channels, you can change your preferences for receiving such advertising by clicking the opt-out link provided in such advertising.
7. WHAT IF YOU DON’T LIKE COOKIES?
8. WHAT ARE YOUR RIGHTS?
8.1 You have the right to request access to all personal data processed by us pertaining to you. We reserve the right to charge a reasonable administrative fee for multiple subsequent requests for access that are clearly submitted for causing nuisance or harm to us. Each request must specify for which processing activity you wish to exercise your right to access and must specify to which data categories you wish to gain access to.
8.2 You have the right to rectification, i.e. to ask that any personal data pertaining to you that are inaccurate, are corrected free of charge. If you submit a request for correction, your request needs to be accompanied of proof of the flawed nature of the data for which correction is asked
8.3 You have the right to withdraw your earlier given consent for processing of your personal data.
8.4 You have the right to erasure, i.e. to request that personal data pertaining to you be deleted if these data are no longer required in the light of the purposes or if you withdraw your consent for processing them. However, you need to keep in mind that a request for deletion will be evaluated by us against:
– Our and a third parties’ interests which may override your interests; or
– Legal or regulatory obligations or administrative or judicial orders which may contradict such deletion.
8.5 You have the right to restriction instead of deletion, i.e. to request that we limit the processing of your personal data if:
– We are verifying the accuracy of your personal data; or
– The processing is unlawful and you oppose the deletion of your personal data; or
– You require your personal data to establish, exercise or defend a legal claim, while we do no longer need your personal data for the purposes listed under Article 3. above; or
– We are verifying whether our legitimate interests override your interests if you exercise your right to object in accordance with Article 3.
8.6 You have the right to object to the processing of personal data if:
– The processing is based on our legitimate interest; and
– You are able to prove that there are serious and justified reasons connected with your particular situation that warrant such objection; and
– Our legitimate interests do not override your interests
However, if the intended processing qualifies as direct marketing, you have the right to object to such processing free of charge and without justification.
8.7 You have the right to data portability, i.e. to receive from us in a structured, commonly-used and machine-readable format all personal data you have provided to us if the processing is based on your consent or a contract with you.
8.8 If you wish to submit a request to exercise one or more of the rights listed above, you can contact our Privacy Officer by sending an e-mail to email@example.com . An e-mail requesting to exercise a right will not be construed as consent with the processing of your personal data beyond what is required for handling your request. Such request should meet the following conditions:
– State clearly which right you wish to exercise; and
– State clearly the reasons for exercising your right if such is required; and
– Your request should be dated and signed; and
– Your request should be accompanied by a digitally scanned copy of your valid identity card proving your identity. If you use the contact form, we may ask you for your signed confirmation and proof of identity.
We will promptly inform you of having received your request. If the request meets the conditions above and proves valid, we will honor it as soon as reasonably possible and at the latest thirty (30) days after having received your request.
If you have any complaints regarding the processing of your personal data by us, you may always contact our Privacy Officer by sending an e-mail to firstname.lastname@example.org . If you remain unsatisfied with our response, you are free to file a complaint with the competent data protection authority.