Privacy Policy

1. Introduction 

This Privacy Policy sets out how Lumine Singapore Pte. Ltd.and itsparent company, Lumine Co., Ltd, and their respective subsidiaries, related entitiesandaffiliates (collectively referred to as “Lumine”, the “Lumine Group”, “us”, “we” or “our”) collects, uses and discloses Personal Data in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). 

By providing Personal Data to us, you agree and consent to our collection, use and disclosure ofsuch Personal Data in the manner described in this Privacy Policy and the other terms contained herein. If you provide us with Personal Data relating to a third party (such as your spouse, children or next-of-kin, for instance), you warrant and represent to us that you have obtained the consent of such third party to disclose/provide the data to us, and that you are authorized to consent to our collection, use and disclosure of such data on behalf of that third party. Personal Data which you provide to us, whether relating to you or a third party shall hereinafter be referred to as “your Personal Data”. 

This Privacy Policy supplements but does not supersede nor replace any other consent you may have previously provided to us in respect of your Personal Data, nor does it affect any right that we may have to collect, useand disclose your Personal Data (including without your consent or otherwise with your deemed consent or from a source other than you) under applicable laws. 

We may, from time to time, amend, update or supplement this Privacy Policy to suit our business needs and/or for consistency and compliance with industry trends and applicable laws. 

2. Personal Data 

(1) In this Privacy Policy, “Personal Data” means information or data that constitutes “personal data” within the meaning of the PDPA -- that is, data, whether true or not, about an individual who can be identified either (a) from such data, or (b) from such data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time. 

(2) Depending on the nature of your relationship or interaction with us, examples of your Personal Data which we may collect from you include but are not limited to the following: 

(a) full name; 

(b) NRIC, FIN, passport or other identification number; 

(c) date of birth; 

(d) race/ethnicity; 

(e) religion; 

(f) photograph or video image; 

(g) telephone number; 

(h) residential/mailing and email address; 

(i) current occupation, employment history, medical history, educational background, income level, and membership with any professional or trade association; and 

(j) bank account and credit card information and other general financial information. 

3. Collection of Personal Data 

We may collect your Personal Data in one or more of the following ways: 

(a) when you order or purchase goods and/or services from us; 

(b) when you submit any form or questionnaire to us; 

(c) when you interact with our staff or customer service officers, whether physically/face-to-face at our retail stores, through telephone or email or otherwise;

(d) when you access our website or establish any online accounts with us or perform an online transaction or use any of our services on our website; 

(e) when you request that we contact you 

(f) when you respond to our request for Personal Data 

(g) when you ask to be included in an email or other mailing list 

(h) when you participate in our marketing or promotional events 

(i) when you participate in our market surveys 

(j) when you apply for a job or position with us 

(k) when we receive references from business partners and third parties; and 

(l) when you provide Personal Data to us for any other reason 

4. Purpose of Collection, Use and Disclosure of Personal Data 

(1) We may collect, use and discloseyour Personal Data for one or more of the following purposes(“Relevant Purposes”): 

(a) If you are a customer 

(i) to provide goods and services to you; 

(ii) to attend and respond to your queries, requests and feedback and to provide customer service; 

(iii) toconduct marketing and promotional activities, such as road shows, contests, lucky draws and other similar events; 

(iv) to determine if you are eligible for any discounts, rewards, privileges or other benefits; and 

(v) to conduct market research and analysiswith the view to developing and improving our goods and services and youroverall customer experience 

(b) If you are seeking employment with Lumine 

(i) to conduct interviews with you; 

(ii) to conduct pre-recruitment checks on you, including obtaining and verifying referrals from your previous employer(s) or other referee(s); and 

(iii) to evaluate and assess your suitability/eligibility for the job or position applied for 

(c) If you are an existing employee of Lumine 

(i) to conduct staff orientation,entry processingand training (whether in Singapore or overseas); 

(ii) to evaluate/assess yourwork performance and your suitability/eligibility for promotion or continuance in or removal from employment or office, salary adjustment, bonus, productivity incentive payments, retrenchment benefits or other employment benefits; 

(iii) to facilitate administrative and support processes relating to your employmentand the termination thereof, including but not limited to payment of salaryand severance payments, processing applications for leave and sponsored training programmes and claims for reimbursement of travel, food, housing, medical and other expenses (as may be applicable);and 

(iv) to conduct internal investigations and proceedings 

(d) General 

(i) to enable you to access and use our website 

(ii) to manage the administrative and business operations of Lumine and comply with internal policies and procedures 

(iii) to conduct investigations or audits or carry out crime and fraud prevention or risk management activities; 

(iv) to comply with legal and regulatory requirements or assist in investigations by law enforcement agencies and other Relevant Authorities; 

(v) to facilitate business asset transactions, including any mergers, acquisitions or business/asset sales; 

(vi) any other purpose separately notified to you and in respect of which we have obtained your consent, including but not limited to the Marketing Purposes as described in Clause 4(2); and 

(vii) any other purpose that is ancillary or incidental to the purposes specified in this Clause 4(1). 

(2) With your prior consent, we may use your Personal Data for certain marketing purposes (“Marketing Purposes”), including, without limitation: 

(a) contacting you, or sending you marketing materials and information regarding our new products and services, special offers, upcoming events and other information that may be of interest to you, including by post, facsimile, text message, voice call or email(collectively, “Marketing Communications”); and 

(b) publishing your Personal Data in our marketing materials. 

You may, at any time, opt out of or withdraw your consent to our use of your Personal Data for Marketing Purposes by following the instructions set out in our Marketing Communications or otherwise by submitting a Withdrawal Notice as described in Clause 10(1). 

5. Disclosure of Personal Data 

We may share Personal Data amongst ourselves (i.e., within the Lumine Group) ordisclose Personal Data to the following third parties for the Relevant Purposes (collectively, “Relevant Third Parties”): 

(a) agents, contractors, data intermediaries (as defined in the PDPA) or other personsthat provide services to us such astelecommunications, mailing, information technology, payment, payroll, data processing, training and market research services; 

(b) our professional advisers such as our auditors or lawyers; 

(c) third parties seeking references in respect of our employees or former employees; 

(d) any judicial, administrative or regulatory body or law enforcement or government agency (collectively, “Relevant Authorities”); and 

(e) any other party whom you authorize us to disclose your Personal Data to. 

6. Transfer of Personal Data out of Singapore 

Where your Personal Data is to be transferred to a country or territory outside Singapore (such as where amember of the Lumine Group or a Relevant Third Party is located outside Singapore, for instance), we will take appropriate steps to ensure that we will continue to comply with our obligations under the PDPA in respect of the transferred personal data while it remains in our possession or under our control and the foreign recipient of the Personal Data is legally bound to provide a standard of protection to the Personal Data that is comparable to the protection afforded under the PDPA, or that such transfer will otherwise be in compliance with the PDPA. 

7. Accuracy of Personal Data 

(1) Subject to Clause 7(2) below, we will take reasonable stepsto ensure that your Personal Data is accurate and complete if the Personal Data (a) is likely to be 

used by us to make a decision that affects you or the individual to whom the Personal Data relates (if you are providing us with Personal Data of a third party), or (b) is likely to be disclosed by us to another organization. 

(2) You represent and warrant that your Personal Data (whether such Personal Data relates to you or a third party) is accurate and complete at the time the data is provided,and you undertake and agree to update us of any changes in such Personal Data as soon as such Personal Data ceases to be accurate or completeby submitting a Correction Request to us as described in Clause 11(3). We will not be liable to you or any other person for relying on inaccurate or incomplete Personal Data in making a decision that affects you or for disclosing inaccurate or incomplete Personal Data to another organization if your Personal Data was inaccurate or incomplete at the time such data was provided to us or if you failed to update us of any changes to such Personal Data when the same had ceased to be accurate or complete. 

8. Protection of Personal Data 

(1) We will endeavour to protect Personal Data in our possession or control against unauthorized access, collection, use, disclosure, copying, modification, disposal or other similar risks (collectively, “Unauthorized Use”) by implementing reasonable security arrangements to prevent such Unauthorized Use, including appropriate administrative, physical and technical measures. 

(2) Notwithstanding the security arrangements described in Clause 8(1), you understand and agree that it is not possible to keep your Personal Data completely secure from, and we will not be liable to you or any other person if anyof your Personal Data in our possession or control is in fact subjected or exposed to Unauthorized Usethrough events beyond our reasonable control, including, without limitation, hacking, spyware, viruses or other forms of cyber attacks or harmful mechanisms. 

9. Retention of Personal Data 

We will destroy, return or otherwise anonymise documents containing your Personal Data as may be appropriate and as soon as it is reasonable to assume that (a) the purpose for which such Personal Data was collected is no longer being served by retention of the Personal Data and (b) retention of such Personal Data is no longer necessary for any legal or business purposes. 

10. Withdrawal of Consent 

(1) You may withdraw any consent given or deemed to be given by you in respect of the collection, use and/or disclosure of Personal Data for any purpose by 

giving reasonable written notice to us in accordance with Clause 12 below (“Withdrawal Notice”). 

(2) Do notethat the withdrawal of your consent in accordance with Clause 10(1) above may attract certain consequences, including, without limitation, our inabilityto provide goods and services to you,or to fulfil any of our contracts with you, or to achieve the Relevant Purposes, or to perform such other tasks as are dependent on our ability to collect, use and/or disclose the Personal Data in respect of which your consent has been withdrawn, all of which may, in turn, lead to the breach and/or early/premature termination of any of your contractual or other arrangement with us and the imposition of applicable penalties and other consequences. You agree that we will not be liable to you for any such consequences arising from or in connection with the withdrawal of your consent. 

(3) Upon receipt of your Withdrawal Notice under Clause 10(1): 

(a) we will, as far as possible, notify you of the likely consequences arising from your withdrawal of consent; and 

(b) should you wish to persist with the withdrawal of your consent after having been notified of the likely consequences thereof, we will cease (and, except where Personal Data is provided to Relevant Authorities under Clause 5(d), cause the Relevant Third Parties to cease)to collect, use and/or disclose your Personal Data as instructed unless the collection, use and/or disclosure of your Personal Data is required or authorized under applicable laws. 

11. Access to and correction ofPersonal Data 

(1) Upon your request (“Access Request”) in writing to us in accordance with Clause 12, we will, as soon as reasonably possible, provide you with (a) your Personal Data that is in our possession or under our control and (b) information about the ways in which such Personal Data has been or may have been used or disclosed by us within a year of your Access Request, unless we are permitted or required to not provide the same under applicable laws. 

(2) We may charge an administrative fee for processing and responding to your Access Request. 

(3) Upon your request in writing to us in accordance with Clause 12 (“Correction Request”), we will, as soon as practicable, (a) correct an error or omission in your Personal Data that is in our possession or under our control and (b) send the corrected Personal Data to every organization to which such Personal Data was disclosed by us within a year before the date the correction was made unless we are permitted or required not to do so under the PDPA. 

12. Contact Details 

If you: 

(a) wish to submit a Withdrawal Notice; 

(b) wish to submit an Access Request or Correction Request; or 

(c) have any questions or feedback regardingour collection, use or disclosure of your Personal Data or our Privacy Policy, 

please submit the relevant notice or request to or contact our Data Protection Officer at 

‘n-kozakai@lumine-sg.com’

13. Governing Law 

This Privacy Policy shall be governed by and construed in accordance with the laws of Singapore, and you hereby submit to the non-exclusive jurisdiction of the Singapore courts.