1. Introduction
1.1 This is the Privacy Policy (“Policy”) of Clovee (“we”, “us”, or “our”) that describes how your personal information is collected, used, and shared when you visit or make a purchase from us.
1.2 This Policy applies to personal information about individuals (customers, vendors, distributors, suppliers, service providers, joint venture/business partners, job applicants, employees) held by us. We will only process your Personal Data in accordance with the Personal Data Protection Act 2010, the applicable regulations, guidelines, orders made under the Personal Data Protection Act 2010 and any statutory amendments or re-enactments made of the Personal Data Protection Act 2010 from time to time (collectively referred to as the “PDPA”) as well as this Policy.
1.3 The PDPA requires us to inform you of your rights in respect of your Personal Data that is being processed or that is to be collected and further processed by us and the purposes for the data processing. The PDPA also requires us to obtain your consent to the processing of your Personal Data. In light of the PDPA, we are committed to protecting and safeguarding your Personal Data.
1.4 By providing your Personal Data to us and/or continuing access to our website (“Site”), you declare that you have read and understood this Policy and agree to us processing your Personal Data in accordance with the manner as set out in this Policy.
1.5 We reserve the right to modify, update and/or amend this Policy from time to time. Please check the Site from time to time to see if there are amendments to this Policy. Any amendments to this Policy will be effective immediately upon publishment. By continuing to use the services and/or access to the Site, you will be treated as having agreed to and accepted those amendments.
2. COLLECTION OF PERSONAL DATA
2.1 The term “Personal Data” means any information in our possession or control that relates directly or indirectly to an individual to the extent that the individual can be identified or are identifiable from that and other information in our possession, such as name, address, telephone number, email address, etc. as well as Sensitive Personal Data as defined under the PDPA, which includes but is not limited to, information pertaining to the physical or mental health or condition of a data subject and religious beliefs.
2.2 When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device.
2.3 Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically collected information as Device Information.
2.4 Also, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, billing address, shipping address, payment. This is called Order Information.
2.5 By Personal Information in this Privacy Policy, we are talking both about Device Information and Order Information.
3. USAGE OF YOUR PERSONAL INFORMATION
3.1 We use the Order Information that we collect generally to fulfil any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations).
3.2 Additionally, we use this Order Information to: - Communicate with you. - Screen our orders for potential risk or fraud. - When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.
3.3 We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site.
4 SHARING OF YOUR PERSONAL INFORMATION
4.1 We will not be sharing your Personal Information with any third parties. However, we may disclose your Personal Data to the following third parties:
- any person under a duty of confidentiality to which has undertaken to keep your Personal Data confidential which we have engaged to discharge our obligations to you;
- any party in relation to legal proceedings or prospective legal proceedings;
- our auditors, consultants, lawyers, accountants or other financial or professional advisers appointed in connection with our business on a strictly confidential basis, appointed by us to provide services to us;
- payment channels including but not limited to financial institutions for purpose of assessing, verifying, effectuating and facilitating payment of any amount due to us in connection with your purchase of our products and/or services;
- government agencies, law enforcement agencies, courts, tribunals, regulatory bodies, industry regulators, ministries, and/or statutory agencies or bodies, offices or municipality in any jurisdiction, if required or authorised to do so, to satisfy any applicable law, regulation, order or judgment of a court or tribunal or queries from the relevant authorities;
- financial institutions, merchants and credit card organisations in connection with your commercial transactions with us;
5 BEHAVIOURAL ADVERTISING
5.1 We use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you.
6. RETENTION OF PERSONAL DATA
6.1 When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.
6.2 Any of your Personal Data provided to us is retained for as long as the purposes for which the Personal Data was collected continues; your Personal Data is then destroyed from our records and system in accordance with our retention policy in the event your Personal Data is no longer required for the said purposes unless its further retention is required to satisfy a longer retention period to meet our operational, legal, regulatory, tax or accounting requirements.
