Our Committment to Data Protection
C.K. Tang Limited ("TANGS") Data Protection Policy governs the management of Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act") and or any advisories or regulations issued from time to time by the Data Protection Commission (or its successor organisation, "the Commission"). Any reference to a Data Protection Officer ("DPO") refers to TANGS’ data protection officer for the time being. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
TANGS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time and made accessible via our website at https://www.tangs.com. Please check back regularly for updated information on the handling of your Personal Data.
If you are a person resident in the European Union, please click here to view the terms and conditions relating to the General Data Protection Regulation (EU) 2016/679 which are also applicable to you.
- i. By interacting with us, visiting our physical and online stores, submitting information to us, or signing up for or purchasing any goods and services offered by us, including signing up for any of our loyalty or rewards program such as the TANGS Membership, you agree and consent to TANGS (including its related corporations and business units) (collectively, the "Companies"), as well as their respective representatives and/or agents (collectively referred to herein with the Companies as "TANGS", "us", "we" or "our") collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies' authorised goods and services providers and relevant third parties in the manner set forth in this Data Protection Policy.
- You are also deemed to have given your consent for the collection, use and disclosure of Personal Data in the following circumstances:
- When you voluntarily provide your Personal Data to us;
- When you are aware of the purposes for which you are providing your Personal Data to us;
- It is reasonable for you to have provided the Personal Data to us in the circumstances; and/or
- In any other circumstances where consent is deemed under Act.
- This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to TANGS in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.
- In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that 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.
- Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport, employment pass or other identification number, telephone number(s), physical mailing address, email address, payment information (e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date), network data and any other information relating to any individuals which you have provided us in any forms (including physical and electronic forms) you may have submitted to us, or via other forms of interaction with you. The list is not exhaustive and apart from the foregoing personal data, we may collect other types of information which is not linked to a specific individual and is anonymous, such as website visitors and number of website users using a particular service in order to improve our customer service to you.
Collection of Personal Data
- Generally, TANGS collect Personal Data in the following ways:
- when you submit an application form or other forms relating to any of our Goods and Services, including applying for the TANGS Membership, making reservations for, alteration to and/ making delivery arrangements for Goods and Services,
- when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
- when you use some of our services, for example, websites and apps including establishing any online accounts with us;
- when you request that we contact you, be included in an email or other mailing list;
- when you respond to our promotions, initiatives or to any request for additional Personal Data;
- when you are contacted by, and respond to, our marketing representatives and customer service officers;
- during CCTV recordings when you visit our Stores;
- when we receive references from business partners and third parties, for example, where you have been referred by them; and
- when you submit your Personal Data to us for any other reasons.
- TANGS uses social media sites (such as Facebook, Instagram, Twitter, etc) to communicate with her customers. As TANGS has no control over your Personal Data that may be collected by these sites, TANGS is not responsible for your Personal Data that you provide to and/or collected by these sites.
- TANGS may collaborate with third party vendors located within the Stores and on TANGS.COM and as such, may have access to Personal Data collected by such third party vendors. Whilst TANGS cannot control or be responsible for the acts of these third party vendors, TANGS will treat all Personal Data which TANGS has access to in accordance with the requirements of the Act.
- When you browse TANGS' website, you generally do so anonymously. TANGS do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
- If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
Purposes for the Collection, Use and Disclosure of Your Personal Data
- TANGS uses the Personal Data to provide you with Goods and Services, process payments, make deliveries, communicate with you about our stores, products, services and promotional offers, update our records and administering membership, loyalty and rewards programs (including TANGS Membership) and generally maintain your accounts with us, display content such as wish lists and customer reviews and recommend merchandise and services that might be of interest to you. TANGS also uses this information to improve its Stores and platform, prevent or detect fraud or abuses of its website and applications, for analytics and tracking, and enable third parties to carry out technical, logistical or other functions on its behalf.
- TANGS does not sell or rent your Personal Data to any third parties. Your personal information may be shared with current or future TANGS entities or subsidiaries, legal and financial institutions which will undertake to respect any individual's rights to privacy and in compliance with the Act.
Transfer of Your Personal DataTANGS will not transfer any of your personal data outside of Singapore unless the transfer conforms to the requirements of the Act.
Security of Personal Data
- TANGS implements appropriate reasonable technical and organisational security measures to safeguard your Personal Data within our control or possession against loss and any unauthorised misuse, access, disclosure, alteration and other similar risk.
- Whilst TANGS takes reasonable care to safeguard the Personal Data in our possession or control, there is always a risk that third parties may unlawfully intercept transmissions while the data is in transmission or in storage. This is the inherent risk of all internet or data transmission and storage. As TANGS cannot entirely ensure the security of any information you transmit or provide, all information is furnished at your own risk.
Withdrawal of Consent to use Personal Data
You can withdraw your consent to the continued use of your Personal Data to TANGS by contacting our Customer Service at (65) 6737 5500 or email firstname.lastname@example.org or login to your online account athttps://www.tangs.com. There is no need to provide any reason for the withdrawal of your consent. Upon receipt of your notice of withdrawal, TANGS will cease to use your Personal Data as soon as practicable.
Right to Access to Your Personal Data
- You may enquire as to whether TANGS is in possession or control of your Personal Data and or the ways in which your Personal Data has been used or disclosed within a year before the date of your request. Any such request must be made in writing to the Data Protection Officer and an administrative fee may be imposed for responding to such a request.
- Subject to the Act, TANGS may not be able to provide access to all of the Personal Data that it holds about you. For example, TANGS may not provide access to Personal Data if such provision could reveal Personal Data relating to another person, if such information is subject to legal privilege, if such provision will be contrary to national interest or if the non-disclosure of access is otherwise permitted by law. If access to Personal Data cannot be provided, the reasons for denying access will be provided upon request, to the extent permitted by law.
Right to Accuracy and Correction of Personal Data
- You should ensure that all Personal Data submitted to us is true, accurate and complete. Failure on your part to do so may result in our inability to provide you with the goods and services you have requested.
- To the extent required by the Act, TANGS will use reasonable efforts to ensure that the Personal Data it uses is sufficiently accurate and complete to minimize the possibility that incorrect Personal Data may be used to make a decision that impacts the person to whom the Personal Data relates, or if such Personal Data is likely to be disclosed to a third party. However, you acknowledge that there may be circumstances where TANGS is entitled to assume such accuracy and completeness, in accordance with law.
- You may correct any erroneous Personal Data held by TANGS by contacting our Customer Service at (65) 6737 5500 or email email@example.com or login to your online account athttps://www.tangs.com. Any unresolved differences as to accuracy or completeness of Personal Data shall be noted in your records. Save as otherwise required under the Act, you may only correct any Personal Data which you have provided to TANGS. TANGS reserves the right to not correct Personal Data to the extent permitted under the Act.
Retention of Your Personal DataPersonal data will be held for as long as it is necessary to fulfil the purpose for which it was collected. TANGS will cease to retain the Personal Data or remove the means by which Personal Data can be associated with particular individuals when it is no longer necessary for legal or business purposes.
Law, Jurisdiction and LanguageThis Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore and you agree to submit to the exclusive jurisdiction of the courts of Singapore.
Contacting the Data Protection OfficerIf you have any questions or feedback relating to your Personal Data or TANGS' Data Protection Policy, please contact C.K. Tang Limited as follows:
Data Protection Officer
Office of Data Protection
C.K. Tang Limited
310 Orchard Road
TANGS will acknowledge receipt of your query or request within 3 working days and will endeavour to resolve your query or request within 30 days from the date of submission. TANGS will inform you in writing if more time is required to investigate and respond to you.
As a matter of policy, we do not attend or respond to anonymous query or request.
15 August 2018
C.K. Tang Limited
Provisions Applicable to Persons in the European Union
Please be informed as follows regarding the processing of your personal data pursuant to Art. 13 of EU Regulation 2016/679 on personal data protection ("Regulations").
- Purposes of processing and consequences should you refuse to provide your personal dataa) Purposes that require data processing: to perform a requested service.
TANGS processes the personal data you provide to allow you to use the services on https://www.tangs.com, which includes requesting information about our products and their availability, requesting assistance, being re-contacted, or reserving an appointment at a Store. For such purposes, TANGS processes your data such as title, name, email address, data relating to your residence (city, country), and date of birth. For the purposes indicated above, providing your personal data is necessary and a refusal to do so will prevent you from using the requested service.
b) Additional purposes: marketing - profiling - sharing of data with TANGS.
With your consent (which is optional), TANGS uses your personal data for marketing purposes, i.e. to send you promotional newsletters, sales, or advertising communications on events, promotional and sales initiatives of TANGS, market research and satisfaction surveys, in addition to performing statistical analyses with anonymous data that has been organized in aggregate format. The marketing activities are completed by email, newsletter, telephone call via operator, sms, mms, chat, instant messaging, social networks and traditional mail, including the sending of invitations to events organized by TANGS or in which TANGS participates. You may at any time indicate the contact method you prefer of those noted above, or may oppose receiving promotional communications through all or just some of the aforementioned communication methods.
With your consent (which is optional), TANGS, at its own points of sale and online through websites or TANGS accounts on social media, collects information relating to your preferences, practices, lifestyle, as well as the details for purchases made, in order to use it to create group and individual profiles ("profiling") which are used to send personalized communications and to perform market research and statistical research with anonymous data, which is organized in aggregate form. The personalized marketing activities are completed by email (newsletter), phone, sms, mms, chat, instant messaging, social network and traditional mail, including invitations to events. You may at any time indicate the contact method you prefer from among those noted above, and you may oppose receiving promotional communications through any or all of the communications methods listed above.
With your consent (which is optional), TANGS uses your personal data for the purposes of sharing it with the companies within the TANGS group, in order to conduct marketing activities on their behalf, i.e. to send you promotional newsletters, sales or advertising communications about events, promotional and sales initiatives for companies in the TANGS group, market research and satisfaction surveys, in addition to performing statistical analyses with anonymous data, organized in aggregate form. Marketing activities are carried out by email, newsletter, telephone calls through operators, sms, mms, chat, instant messaging, social networks, and traditional mail, including sending invitations to events organized by companies in the TANGS group or in which the companies of the TANGS group participate. You may indicate at any time the contact method you prefer from among those noted above and you may oppose receipt of the promotional communications through all or some of the communication channels noted above. For the marketing, profiling and data sharing activities TANGS uses data such as your title, name, email address, data relating to your place of residence (city, country), your date of birth, data relating to interactions with our digital initiatives (websites, social media), products viewed, requested and/or purchased, participation in events organized by TANGS, or in which TANGS participates.
It is optional to provide your personal data for the aforementioned purposes of marketing, profiling and data sharing, and any refusal to do so shall have no effect on your registration with https://www.tangs.com.
- Methods and legal bases for the processing
TANGS processes your personal data with or without the aid of electronic instruments, based on logic and procedures that are consistent with the purposes indicated below and in accordance with the Regulations, including the confidentiality and security terms. You may provide the data when registering with https://www.tangs.com, making purchases when visiting our Stores, or when you interact with our digital initiatives (websites, social media, etc), or during events that are organized by TANGS or in which TANGS participates. In accordance with the Regulations, the personal data concerning you that is acquired from you in each instance or from authorized third parties is used to update and correct the information that was previously collected. TANGS processes your personal data based on the following criteria of legitimacy:
- your consent
- TANGS's legitimate interest in performing its activity
- the performance of a specific request from you
- the fulfilment of legal obligations
- Communication of your personal data to third parties
The personal data is accessible to our duly authorized personnel based on criteria of need and is communicated to third parties in the following cases:
(a) when the communication is required by law and applicable regulations with respect to legitimate third parties who receive the data, such as public entities and authorities for the respective institutional purposes;
(b) communication to third parties in case of extraordinary operations (e.g. mergers, purchases, disposal of business, etc.)
Your personal data is also shared with our service providers, e.g. for services of a technical and organizational nature which are functional for the purposes indicated above, such as independent associates, including partners, e.g. companies that manage our website, companies specialized in market research or data processing, advertising companies, etc. We provide these parties with the data needed to perform the services agreed to and they act as Data Processors, based on the instructions they receive from TANGS. TANGS does not disclose your data to third parties for them to be able to use it for their own marketing or profiling purposes.
- Transfer of personal data outside the European Union
(applicable if, and only if, TANGS were to establish a business presence within the European Union)
Some of the aforementioned parties may also be established outside the European Union, in countries that do not provide an adequate level of personal data protection according to the standards established by the Regulations. TANGS takes the necessary precautions for data to be lawfully transferred as required under the applicable laws of Singapore. You may request information regarding the transfer of your personal data outside of the European Union at any time by contacting TANGS or TANGS' Data Protection Officer at the addressed indicated above.
- Maintaining of personal data
The personal data processed to respond to a specific request from you is kept for the time needed to perform the requested service. For the purposes of marketing, profiling and sharing data with companies of the TANGS group, the data is kept for the period of time that is strictly necessary to achieve the aforementioned purposes, within the limits granted by the Regulations. In particular, personal data of persons in the European Union will be processed for a period of 12 months for profiling purposes and 24 months for marketing purposes. You may request that your data be deleted for such purposes and oppose the processing of data for marketing purposes at any time.
- Data controller and data protection officer
For purposes of the Regulations, the Data Controller is TANGS, with registered office at 320 Orchard Road, Singapore 238864. The Data Protection Officer is domiciled at the registered office of the Controller and may be contacted at the following email address: firstname.lastname@example.org.
- Your rights
You may contact TANGS in its capacity as Data Controller or the Data Protection Officer for purposes of the Regulations at the addresses indicated above for an updated list of our data processors (i.e. our service providers), the parties to whom the data is disclosed and to exercise your rights per Art. 15 et seq. of the Regulations at any time; to obtain confirmation of whether or not your data exists, to check its content, source, accuracy, to request that it be supplemented, updated, corrected, deleted, anonymized, to request that it be transferred, that processing be limited, to oppose processing for legitimate reasons, e.g. opposing marketing activities, or to submit a claim to the Supervisory Authority (the Personal Data Protection Authority) of the European Union.