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Privacy Policy

I. INTRODUCTION

At SutaGram, we take our customer’s privacy seriously and only collect, record, hold, store, disclose, transfer and use your personal data as outlined below (“Privacy Policy”).

Your privacy is important to us, and data protection is a matter of trust and law. SutaGram shall therefore only use your information in the manner set out in this Privacy Policy. SutaGram will only collect information necessary and relevant to SutaGram’s dealings with you. SutaGram will only keep your information for as long as it is relevant for the purposes for which it was collected, as otherwise required to by law.

You can visit the SutaGram’s websites (“SutaGram Network”) and browse without having to provide personal details. When visiting the SutaGram Network, you will remain anonymous and we cannot identify you unless you have a SutaGram Network account are logged on with your user name and password.

SutaGram is committed to complying with the Personal Data Protection Act 2012. If you have any comments, suggestions or complaints, please contact us (and our Data Protection Officer) by email at our address below.

Please review this Privacy Policy carefully prior to visiting or using the SutaGram Network or otherwise providing any personal data. By visiting or using any of the pages available on the SutaGram Network on which this Privacy Policy or a link to this Privacy Policy appears, you are deemed to agree to the terms of this Privacy Policy.

If you wish to access, amend or remove any of your personal data in our possession, please refer to clause V for the required procedure.

II. Collection of Personal Data

A. SutaGram’s collection of personal data

Personal data means data about you, where you can be identified from either that particular data, or from that data and other information which SutaGram has or is likely to have access to. Personal data that SutaGram commonly collects from you typically includes, amongst other things, your name, addresses, telephone (landline and mobile) numbers, e-mail addresses, identification numbers, nationality, date of birth and credit card information.

SutaGram only collects personal data directly from you wherever possible, including but not limited to during or before you:

  1. set up a SutaGram Network account;
  2. sign up to receive information from SutaGram;
  3. order products through the SutaGram Network;
  4. provide feedback or complaints through the SutaGram Network;
  5. participate in any SutaGram Network social media offerings (e.g. signing up through SutaGram’s Facebook page); and/or
  6. participating in any SutaGram related marketing activity.

You must only submit to SutaGram, SutaGram’s authorised agent or the SutaGram Network, information which is accurate and not misleading. Further, you must keep this information up to date and inform SutaGram of changes. SutaGram reserves the right to request for documentation to verify any information provided by you. If you do not to submit your personal information to SutaGram or subsequently withdraw your consent to SutaGram’s use of the same, SutaGram may not be able to provide you with our services. You may access and update your personal information submitted to us at any time as described below. If you provide a third party’s personal information to SutaGram, you are confirming to us that you have obtained the required consent from such third party to share and transfer to SutaGram his/her personal information.

In addition to the personal data you provide to SutaGram, we may also collect certain of your information not considered to be personal data. SutaGram collects this information in order to improve the SutaGram Network and other online services. Such non-personal data may include your IP address, browser-type, your interactions with the SutaGram Network, shopping habits, preferences and information about your lifestyle or preferences such as your hobbies and interests and other types of non-personal data.

If you have granted SutaGram the relevant permissions, SutaGram may also receive your personal information from third party sources, including but not limited to information from commercially available sources (e.g. public databases and data aggregators). If you sign up for SutaGram using a social media account, link your SutaGram Network account to a social media account or use certain SutaGram Network social media features linked to a third party social media provider, SutaGram may access information about you which you have voluntarily provided through your social media provider in accordance with such provider’s policies. SutaGram will manage such personal data which SutaGram has collected in accordance with this Privacy Policy. For the avoidance of doubt, this Privacy Policy governs your entire period of use of the SutaGram Network, from your first access, until you validly require SutaGram to remove your personal data in accordance with the terms set out below.

B. Collection of personal data by other websites

The SutaGram Network may use plug-ins from third party websites (each a “Third Party Site”). If you access a page on the SutaGram Network that contains a plug-in, your browser may establish a direct link to the servers of a Third Party Site, and information may be sent directly to or from your browser to or from such Third Party Site. Thereafter, if you are logged on such Third Party Site when you browse the SutaGram Network, the Third Party Site may directly link your visit to your SutaGram Network account. The Third Party Site may use such information for advertising and market research purposes, and may adapt its pages accordingly. If you do not wish such Third Party Site to link information collected via the SutaGram Network to your account with such Third Party Site, please log out of such Third Party Site before visiting the SutaGram Network.

C. Special Notice – if you are under 13

SutaGram Network is not aimed at persons under the age of 13. SutaGram will not deliberately collect, use, provide or process in any form any personal data of such persons. If you are under 13, we therefore ask you not to send SutaGram your personal data (for example, your name, address and email address).

If you are under the age of 13 and nevertheless wish to ask SutaGram a question or use the SutaGram Networks in any way which requires you to submit your personal data to SutaGram, please get your parent or guardian to do so on your behalf.

III. Use of Cookies

The term “cookies” used herein, refers to cookies and other similar technologies covered by the EU Directive on privacy in electronic communications.

What is a cookie? Cookies are small data files that your browser or application places on your computer or mobile device. Cookies assist your browser or application navigate a website. Cookies themselves cannot collect any information stored on your device.

We use cookies to reduce the number of times you need to enter your password. Cookies help us provide to you with information targeted in accordance to your interests, and to make your browsing experience as smooth as possible. We may offer features that are only available through the use of a cookie.  Other types of cookies are used to monitor and improve our website’s functionality and performance. To protect your privacy, your browser only gives a website access to the cookies it has already sent to you.

Why do we use cookies? SutaGram continually strives to provide you with the best user experience possible when visiting our sites. Therefore, we use cookies to learn more about the way you interact with our content and help us to improve your experience when visiting us.

Cookies remember the type of browser you use and which additional browser software you have installed. They also remember your preferences, such as language and region, which remain as your default settings when you revisit the website. Cookies also allow you to rate pages and fill in comment forms.

Some of the cookies we use are session cookies and only last until you close your browser, others are persistent cookies which are stored on your computer or device for longer. Click here for more information on the cookies SutaGram uses.

How are third party cookies used? For some of the functions within our websites we use third party suppliers, for example, when you visit a page with videos embedded from or links to YouTube. These videos or links (and any other content from third party suppliers) may contain third party cookies and you may wish to consult the policies of these third party websites for information regarding their use of cookies. Click here for more information on the third party cookies SutaGram uses.

How do I reject and delete cookies? We assume your consent to SutaGram’s use of cookies when you visit and use our sites and most browsers are automatically set to accept cookies. You can modify your browser to decline cookies (if your browser permits you to do so), although in such a case you may not be able to access certain features on SutaGram’s sites or some interactive features offered on SutaGram’s site may be restricted or rendered inoperable. Should you wish, you can reject or block the cookies set by SutaGram or the websites of any third party suppliers by changing your browser settings. See the Help function within your browser for further details. Please Note: if you reject SutaGram’s use of cookies you will still be able to visit our sites but some of the functions may not work correctly.

For details on how to delete or reject cookies and for further information on cookies generally, please visit www.allaboutcookies.org

IV. Use and Disclosure of Personal Data

A. Use and Disclosure

The personal information SutaGram collects from you may be used, combined, or shared with third parties (including related companies, third party service providers, and third party sellers), for some or all of the following purposes:

  1. To facilitate your access to the SutaGram Network and/or use of SutaGram’s services;
  2. To your process orders submitted via the SutaGram Network.
  3. To deliver to you the products purchased via the SutaGram Network.
  4. To provide you with updates on the delivery of the products or services, and for customer support purposes;
  5. To provide, maintain, protect and improve the SutaGram Networks, and products, services, content and interactivity provided thereon, to develop new content, and to protect SutaGram and our users. SutaGram also use this information to offer you tailored content – like giving you more relevant content and ads;
  6. For information comparison, including but not limited to third party verification of the accuracy of information provide by you;
  7. In addition, information provided by you will be used by SutaGram, SutaGram’s authorised agent, or other third party, to administer your account (if any) with SutaGram; verify and transact your online payments; audit the SutaGram Network’s data downloads; identify visitors to the SutaGram Network; carry out research on SutaGram’s users’ behaviour and demographics; provide you with information, including information about SutaGram’s third party sellers’ products and services. Such information will be provided to you if you have indicated that you do not object to being contacted for these purposes;
  8. By registering for a SutaGram account or otherwise providing SutaGram with your personal information through the SutaGram Network, SutaGram will also use your personal information to send you marketing and/or promotional materials about our or third party sellers’ products and services from time to time. You have an option to unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material. SutaGram may also use your information to  contact you through newsletters from us and from our related companies; and
  9. In exceptional circumstances, SutaGram may be required to disclose your personal information, for instance when there are grounds to believe that the disclosure is necessary to prevent a threat to life, limb, liberty or health; for law enforcement purposes (including investigations, compliance with a court order or other regulatory requirements in any jurisdiction where SutaGram operates); to prevent terrorism and/or money laundering, or for fulfilment of legal and regulatory requirements and requests.

In addition, for the aforementioned reasons, as well as to enforce the Terms of Use related to the SutaGram Network, SutaGram may share your personal information with third parties and our affiliates, and such parties may include SutaGram’s advertising, marketing and promotional agencies to help us deliver and analyse the effectiveness of SutaGram’s advertising campaigns and promotions; third parties required to deliver a product or service to you, such as a postal service; third party providers of services, such as data processing; or web analytics tool providers, such as Google.

Recipients of your personal data may be located outside Singapore. You agree that we may transfer your personal data to our affiliates, subsidiaries and/or other third parties located outside of Singapore. SutaGram will use reasonable endeavours to ensure that recipients of your personal data provide a standard of protection for your personal data comparable to the protection afforded under the Personal Data Protection Act 2012 (No. 26 of 2012).

V. Amendments to Personal Data

If you wish to object to our continued use and/or disclosure of your personal data for any reason, or if you otherwise wish to access, change, update or remove your personal data, you can do this by contacting SutaGram at our email address below. You may decline to receive e-mails by clicking on ‘unsubscribe’ in any marketing e-mail you receive. If you have a SutaGram Network account, you may access your details by logging into your account on the SutaGram Network. Here you may access, change and remove your personal details. You undertake take due care to treat your SutaGram username, password and order details in a confidential manner and not make it available to unauthorised third parties. Except as otherwise stated, SutaGram cannot assume any liability for misuse of your SutaGram Network username, password or order details. Please note that SutaGram reserves the right to charge a reasonable administrative fee for retrieving your personal information records.

Please note that if you request for removal of your personal data from SutaGram’s records, depending on the nature of your objection, upon removal of such personal data, SutaGram may not be in a position to continue to provide to you our content, products or services or perform any contract that we may have with you; SutaGram reserves our rights and remedies in this regard.

VI. Security of Your Personal Data

A. Security

SutaGram ensures that all information collected will be safely and securely stored. SutaGram’s security measures include but are not limited to the following:

  1. Restricting access to personal data stored on SutaGram’s systems;
  2. Maintaining technology products to prevent unauthorised computer access; and
  3. Securely destroying your personal data when it is no longer needed for any legal or business purpose.

No method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, SutaGram strives to protect your personal data and are constantly reviewing and enhancing our security protocols to ensure that your personal data is not subject to unnecessary risks. If you believe that your privacy has been breached, please contact us at our e-mail address below.

B. Passwords

Please maintain the security of your password. It is the key to your account. Use unique numbers, letters and special characters, and do not share your SutaGram Network password to anyone. When using a shared computer, please remember too log out of your account and close the browser. If you disclose your password to any other person, you will be liable for any and all (i) actions taken on your account; and (ii) consequences thereof. If you lose control of your password, you may lose substantial control over your personal data and other information submitted to SutaGram. Please be aware that loss of control of your password could subject you to legally binding actions taken on your behalf. If you know or believe your password has been compromised for any reason, immediately contact SutaGram and change your password.

C. No Spam, Spyware, or Viruses

Spam, spyware or viruses are not permitted on the SutaGram Networks. Please set and maintain your communication preferences so that we send communications to you as you prefer. You are not licensed or otherwise permitted to add other users (even a user who has purchased an item from you) to your mailing list (email or physical mail). Do not send any messages which contain spam, spyware or virus via the SutaGram Network, doing so may result in the suspension or deletion or your account. To report any suspicious messages, please contact SutaGram at our email address below.

VII. Changes to the Privacy Policy

SutaGram reserves the right to amend this Privacy Policy at any time. Any changes will be published on the SutaGram Network. We encourage you to review this Privacy Policy periodically in order for you to stay notified of any changes.

Your continued use of the SutaGram Network and acceptance of our services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.

VIII. Miscellaneous

YOU ACKNOWLEDGE AND AGREE THAT SutaGram HAS THE RIGHT TO DISCLOSE YOUR PERSONAL DATA TO ANY LEGAL, REGULATORY, GOVERNMENTAL, TAX, LAW ENFORCEMENT OR OTHER AUTHORITIES OR THE RELEVANT RIGHT OWNERS, IF SutaGram HAS GROUNDS TO BELIEVE THAT DISCLOSURE OF YOUR PERSONAL DATA IS NECESSARY FOR THE PURPOSE OF MEETING ANY OBLIGATIONS, REQUIREMENTS OR ARRANGEMENTS, WHETHER VOLUNTARY OR MANDATORY, AS A RESULT OF COOPERATING WITH AN ORDER, AN INVESTIGATION AND/OR A REQUEST OF ANY NATURE BY SUCH PARTIES. TO THE EXTENT PERMISSIBLE BY APPLICABLE LAW, YOU AGREE NOT TO TAKE ANY ACTION AND/OR WAIVE YOUR RIGHTS TO TAKE ANY ACTION AGAINST SutaGram FOR DISCLOSING YOUR PERSONAL DATA IN THESE CIRCUMSTANCES.

This Privacy Policy is governed by and shall be construed in accordance with Singapore law including without limitation the provisions of the Evidence Act (Chapter 97), Electronic Transactions Act (Cap. 88) and the PDPA, without giving effect to any principles of conflicts of law. You agree to submit to the non-exclusive jurisdiction of the Singapore courts.

Contacting SutaGram
If you wish to withdraw your consent to our use of your personal data, request access and/or correction of your personal information, have any queries, comments or concerns, or require any help on technical or cookie-related matters, please feel free to contact us (and our Data Protection Officer) at office@sutagroup.com.