Schedule 1

PRIVACY POLICY

 

SINGAPORE STRAITS WINE COMPANY PTE LTD. (“we” or “us”) is committed to protecting and respecting your privacy.

 

  1. This policy (together with our terms of use and any other documents referred to on it) sets out the basis on which any personal data (the “Data”) we collect from you, or that you upload, will be processed by us. Please read the following carefully to understand our views and practices regarding your Data and how we will treat it.

 

  1. By accepting our Terms of Use, you consent to the collection, use, disclosure and transfer of your Data in the manner and for the purposes set out below.

 

 

INFORMATION WE MAY COLLECT

 

  1. We may collect and process the following data:

 

  • information that you provide by filling in forms on https://straitswine.com/ (“our Platform”), including information provided at the time of registering to use our Platform, subscribing to any services provided by us, posting material, reporting a problem with our Platform, or requesting further services;

 

  • details of transactions you carry out through our Platform;

 

  • details of your visits to our Platform and the resources that you access; and

 

  • if you contact us, a record of that correspondence.

 

 

IP ADDRESSES

 

  1. We may also collect and process information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is statistical data about our users’ browsing actions and patterns, and does not identify any individual.

 

 

COOKIES

 

  1. Our Platform uses cookies to distinguish you from other users of our Platform. This helps us to provide you with a good experience when you browse our Platform and also allows us to improve our Platform.

 

 

SECURITY

 

  1. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share the password with anyone.

 

  1. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your Data, we cannot guarantee the security of your Data transmitted to our Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

 

 

 

PURPOSES OF COLLECTION OF PERSONAL DATA

 

  1. We use information held for the following purposes:

 

  • to ensure that content from our Platform is presented in the most effective manner for you and for your computer;

 

  • to provide you with information, products or services that you request from us, and to otherwise carry out our obligations arising from any contracts entered into between you and us;

 

  • to provide you with information, products or services which we feel may interest you, where you have consented to be contacted for such purposes;

 

  • to allow you to participate in interactive features of our service, when you choose to do so;

 

  • processing, handling and corresponding with you in relation to your enquiries, feedback, complaints, requests and applications to us;

 

  • providing after sales service or support or customer care;

 

  • processing payment or credit transactions;

 

  • 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;

 

  • transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities for the aforementioned purposes; and

 

  • carrying out whatever else is reasonable or related to or in connection with the above and our provision of goods and/or services to you.

 

 

CONSENT TO COLLECTION, USE, DISCLOSURE OF PERSONAL DATA

 

  1. By providing your Data to us, you consent to the collection, use, disclosure and/or transfer of your Personal Data for the purposes set out in this Privacy Policy (“Purposes”).

 

  1. Please ensure that you speak to others before providing their Data to us. Kindly inform them that our collection, use and disclosure of their Data is solely for the Purposes. By providing the Data of others to us, you represent and warrant that such person consents to our collection, use and disclosure of Personal Data for the purposes set out in this Privacy Policy.

 

  1. You may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the Purposes by submitting your request to us in writing at the contact details provided below. Should you withdraw your consent to the collection, use or disclosure of your Personal Data for any of the Purposes, it may impact our ability to proceed with your transactions, agreements or interactions with us. Upon receipt of your request, we will inform you of the consequences of the withdrawal of your consent. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitled to at law).

 

 

DISCLOSURE OF YOUR INFORMATION

 

  1. We may disclose your Data to any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in the Companies Act (Cap 50).

 

  1. We may disclose your Data to third parties:

 

  • for the purposes of providing products or services that you request from us, fulfilling our obligations arising from any contracts entered into between you and us, processing payments in connection therewith or otherwise in connection with your use of our Platform, in which case your Data may be provided to our third party service providers;

 

  • in the event that we sell or buy any business or assets, in which case we may disclose your Data to the prospective seller or buyer of such business or assets;

 

  • if we or substantially all of our shares or assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

 

  • if we are under a duty to disclose or share your personal data, in order to comply with any legal obligation (including any direction from a governmental or regulatory body or law enforcement) or in order to enforce or apply our terms of use.

 

 

YOUR RIGHTS

 

  1. Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Data to these websites.

 

 

ACCESS AND CORRECTION

  1. The PDPA gives you the right to access your Data. Your right of access can be exercised in accordance with the PDPA. Any access request may be subject to an administrative fee at our rates then in force to meet our costs in providing you with details of the information we hold about you.

 

  1. In the event that you wish to correct and/or update your Data in our records, you may inform us in writing of the same.

 

  1. You may access, correct, and/or update your Data by contacting us at the contact details provided below. We will respond to requests regarding access and correction as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

 

ACCURACY

 

  1. We endeavour to ensure that all decisions involving your Data are based upon accurate and timely information. While we will do our best to base our decisions on accurate information, we rely on you to disclose all relevant information and to inform us of any significant changes. As such, you are kindly requested to disclose all relevant information, inform us of any changes and to ensure that all your Data that is submitted to us is current, complete, accurate, true and correct.

 

 

RETENTION OF PERSONAL DATA

 

  1. We may retain your Data for so long as is necessary for the purpose for which it was collected, or for so long as required or permitted by applicable laws. We will cease to retain your Data, or remove the means by which the Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Data was collected and is no longer necessary for legal and business purposes.

 

 

CHANGES TO OUR PRIVACY POLICY

 

  1. Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail.

 

 

CONTACT

 

  1. Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to our Data Protection Officer at:

 

Attention to : Singapore Straits Wine Company

Email : [ ecommerce@sswc.com.sg ]

Telephone number : [ +65 6593 6333 ]

Mail address : [  Singapore Straits Wine Company
6 Harper Road, Leong Huat Building #01-02, Singapore 369674 ]

 

 

Schedule 2

ACCEPTABLE USE POLICY

 

  1. This acceptable use policy sets out the terms between you and SINGAPORE STRAITS WINE COMPANY PTE LTD. (“we” or “us”) under which you may access our platform, https://straitswine.com/ (“our Platform”). This acceptable use policy applies to all users of, and visitors to, our Platform.

 

  1. Your use of our Platform means that you accept, and agree to abide by, all the policies in this acceptable use policy, which form part of and supplement our Terms of Use for our Platform.

 

 

PROHIBITED USES

 

  1. You may use our Platform only for lawful purposes. You may not use our Platform:

 

  • in any way that breaches any applicable local or international laws or regulations;

 

  • in any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect;

 

  • to send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards as set out in our prevailing terms and conditions as amended from time to time; and

 

  • to knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

 

  1. You also agree:

 

  • not to reproduce, duplicate, copy or re-sell any part of our Platform in contravention of the provisions of our terms of use for our Platform; and

 

  • not to access without authority, interfere with, damage or disrupt:

 

  • any part of our Platform;

 

  • any equipment or network on which our Platform is stored;

 

  • any software used in the provision of our Platform; or

 

  • any equipment or network or software owned or used by any third party.

 

 

CONTENT STANDARDS

 

  1. These content standards apply to any and all material which you upload on our Platform (“Contributions”).

 

  1. You must comply with the spirit of the following standards as well as the letter. The standards apply to each part of any Contribution as well as to its whole.

 

  1. Contributions must:

 

  • comply with Singapore law, in particular, the Personal Data Protection Act 2012 (No. 26 of 2012), and the laws of any country from which they are posted; and

 

  • be placed in the correct and appropriate categories.

 

  1. You shall be responsible for the authenticity, truthfulness, accuracy and origin of the Contributions. You must ensure that you either have all ownership rights to the Contributions uploaded or all rights allowing you to upload the Contributions.

 

  1. Contributions must not:

 

  • infringe any copyright, database right or trade mark of any other person;

 

  • be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence;

 

  • be threatening or abusive, invade another’s privacy, or cause or be likely to cause annoyance, alarm, inconvenience or needless anxiety to any other person;

 

  • be used to impersonate any person, or to misrepresent your identity or affiliation with any person;

 

  • give the impression that they emanate from us, if this is not the case;

 

  • advocate, promote or assist any unlawful act such as (by way of example only) copyright infringement or computer misuse; or

 

  • advertise, promote or market any products or services by third parties or yourself.

 

  1. We reserve the right to request that you amend or delete the Contributions if it is found that any of the Contributions posted by you is in contravention of this acceptable use policy.

 

  1. Where you choose to terminate your account with us, you may delete all previous Contributions made by you and retain a copy of the same.

 

 

SUSPENSION AND TERMINATION

 

  1. We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our Platform. When a breach of this policy has occurred, we may take such action as we deem appropriate.

 

  1. Failure to comply with this acceptable use policy constitutes a material breach of the terms of use upon which you are permitted to use our Platform, and may result in our taking all or any of the following actions:

 

  • immediate, temporary or permanent withdrawal of your right to use our Platform, including closure or suspension of your account on our Platform;

 

  • immediate, temporary or permanent removal of any posting or material uploaded by you to our Platform;

 

  • issuance of a warning to you;

 

  • legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach;

 

  • further legal action against you;

 

  • disclosure of such information to law enforcement authorities as we reasonably feel is necessary.

 

  1. We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

 

 

CHANGES TO THE ACCEPTABLE USE POLICY

 

  1. We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our Platform.

 

 

 

 

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