We at Einmilk (“Einmilk” and include such other brands, marks of AE Solution Pte Ltd and its associated companies and subsidiaries) take your privacy seriously and this Policy sets out the basis which Einmilk may collect, use, disclose or otherwise process personal data of our customers whether through the Einmilk website at https://www.einmilk.com (“Site”), or otherwise in the course of our business operations in accordance with the Personal Data Protection Act (“PDPA”).
This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
By accessing the Site and/or providing any personal data to Einmilk, you hereby acknowledge that you have read this Policy and that you consent to the collection, use and disclosure of any personal data by Einmilk in accordance with this Policy. If you do not consent to the terms of this Policy, please do not access the Site or provide any personal data to Einmilk.
2. What is Personal Data?
“Personal data” means data about a person who can be identified (i) from that data, or (ii) from that data and other information to which Einmilk has or is likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name and identification information of yourself and your children’s such as NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
3. Collection of Personal Data
We gather various types of personal data of our users and customers, as explained more fully below.
- Data that is voluntarily provided. Einmilk collects personal data that you voluntarily provide to us, whether through the Site or other platforms or channels (such as through email, telephone and other forms of communication). At various places on the Site, or in the course of obtaining the services provided by Einmilk, you may be required to provide certain personal data such as your full name, email address, address, country of residence, telephone number and other personal information, in order to access or use certain features or services of the Site, or to otherwise obtain our services. For example, personal data may be collected when you register an Account, make a purchase, enter a contest, promotion or survey, fill up a form, provide comments, suggestions or feedback, or when you contact our customer service or helpdesk via email, phone or other channels. You can always choose not to provide your personal data, but you may not be able to access or use certain features or services of the Site or to obtain certain services from us.
- Notwithstanding the generality of the foregoing, whilst we generally do not collect your personal data unless it is provided to us voluntarily by you directly, there may be occasions we obtain your personal data through a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the Personal Data Protection Act 2012 (“PDPA”) or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
4. How do we use your personal data?
Generally, we collect personal data in order to provide our products and services to you and to personalise and improve our services and your user and customer experience with Einmilk. Personal data collected by Einmilk may be used:
- to process, record, monitor and fulfil your orders and deliveries;
- to plan and schedule routes for deliveries;
- to verify and process your personal particulars and payment;
- to communicate with you, including to confirm and update you on the status of your orders and deliveries and respond to your queries and requests;
- to improve our products or services;
- to inform you of promotions, offers, surveys, events, products and services, which may be of interest to you;
- to conduct marketing research, user profile and statistical analysis;
- to customise your online experience according to your chosen interests and preferences and enhance your current and future visits to the Site and customer experience with us;
- to update and back-up our records;
- to reduce credit risk, detect and protect us against error, fraud and other criminal activity;
- to comply with the law, the requests of law enforcement and regulatory officials, or orders of the court;
- to enforce our legal rights and remedies; or
- for such other purposes notified to you on or before collection or use of the data.
The purposes listed herein may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
5. Who do we disclose your personal data to?
We do not rent, trade or sell personal data. Your personal data will not be disclosed by Einmilk to any third party, except:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents and other organisations Einmilk has engaged to perform any of the functions listed in clause 4 above; or
- where you expressly consent to such disclosure; or
- where such disclosure is required or permitted by applicable law, statute, stock exchange regulation or by-law, regulatory or governmental order or court order.
From time to time, we may collaborate with other third parties to organise joint marketing and promotional campaigns, offers or contests, and may require disclosure of your information to such third parties. For example, where a Promotion or Voucher Code is specially offered to customers of our third-party partner, we may share your information with that partner to the extent relevant to such promotional campaign. In some cases, you may not be able to enjoy the promotion, offer or participate in the contest, unless you consent to disclosure to our partner of your information. “Voucher Code” (or “Promotion Code”) refers to any credits, vouchers, coupons or codes offered by Einmilk for use in the purchase of goods from Einmilk.
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, as long as the personal data is handled in accordance with this Policy and all applicable laws. Einmilk will ensure recipients of your personal data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA.
6. How long do we retain your personal data?
Personal data provided by you will be retained as long as the purpose for which the data was collected continues. Thereafter, Einmilk will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect Einmilk’s interests.
7. Protection of Personal Data
- As part of our service fulfilment, a User Account will be created for you. You will generate your user ID and password. We ask that you take steps to protect against unauthorised access or use of your Account. You are responsible for any loss, theft and compromise of your password and Account Information, and any activity on your Account that takes place through unauthorised password use.
- To protect your privacy and personal data, we have put in place security arrangements such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis. We believe our administrative, physical and technical measures are reasonably appropriate to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
- Despite our best efforts, no security measures are impenetrable. Unauthorised entry or use, hardware or software failure, and other factors may compromise the security of your personal data. Einmilk does not warrant or guarantee in any way that your personal information or private communications will always remain private and/or safe. Einmilk hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us, except to the extent caused by our fault or negligence.
8. Linked Sites
Einmilk may provide links to other sites (“Linked Sites”) that may be of relevance and interest to you. Einmilk has no control over and is not responsible for the privacy practices and the content of such Linked Sites, and expressly disclaims all liabilities and responsibilities arising or in relation to any Linked Sites.
In order to improve our products and services, we collect data by way of “cookies”. Cookies help us measure the number of visits, average time spent, page views and other statistics relating to your access to the Site. This information allows us to better administer the Site, and provide a more tailored and user-friendly service to our Site visitors. Cookies also enable you to use or access certain features or services of our Site, including the shopping cart and check-out features. For example, cookies help us store preferences or retrieve products in your shopping cart between visits, from our servers. Cookies are small data files that are sent to your browser from our Site and are stored on the hard drive of your computer or device. Each time you visit our Site from the same computer or device, the cookie will be retrieved from your computer or device, enabling our Site to recognise your computer or device as having previously visited our Site and thereby increase the functionality of our Site on your computer or device. Our cookies cannot be used to get data from your hard drive, to get your email address or any other data that can be traced to you personally. Most web browsers and devices can be set to notify you when you receive a cookie or to prevent cookies from being sent; if you use these features, you may limit the functionality we can provide you when you visit our Site.
10. How to access and correct your personal data?
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request 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).
11. Data Protection Officer
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact Number: +65 6591 8729
Please note: Our operating hours are 9 am to 5.30pm, Monday to Friday.
Do provide your name, contact number, email address and all relevant details along with your question or concern, so that we can review and respond to your question or concern in an efficient and effective manner.
12. Deletion of Account & Unsubscribe from Service
- The information we gather is in an effort to offer you a superior online shopping experience that is customised. You may be able to access, correct or update certain information as explained in Section 10 above. When you update information, however, we may maintain a copy of the unrevised information in our records. Such records will be handled in accordance with the Policy stated herein.
- You may request deletion of your account by sending an email to firstname.lastname@example.org or calling us at our operating hours (Monday to Friday, from 9 am to 5.30pm) at +65 6591 8729. Please note that some information may remain in our private records after deletion of your account. We may use any aggregated data derived from or incorporating your personal data after you delete your account, but not in a manner that would identify you personally unless permitted by law or are in line with the Policy stated herein.
- If you do not wish to receive email or other communications from us, you can unsubscribe from our mailing list by using the unsubscribe facility that may be provided with such email or communication or contact us at email@example.com at our operating hours (Monday to Friday, from 9 am to 5.30pm) at +65 6591 8729.
13. Right to Amend Policy
Einmilk reserves the right to revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
14. Governing Law
This Policy is governed by and shall be construed in accordance with Singapore law and agree to submit to the exclusive jurisdiction of the Singapore courts.