Lovevery Privacy Notice for Singapore Residents
1. Introduction
1.1 This Privacy Notice (this “Notice”) for Singapore Residents supplements the information contained in the general Privacy Statement (“Privacy Statement”) of Lovevery, Inc., Lovevery Europe B.V., Lovevery Australia Proprietary Limited, and their respective affiliates (“Lovevery,” “we,” or “us”), which is incorporated in this Notice by this reference.
1.2 We adopt this Notice to comply with our obligations under the Singapore Personal Data Protection Act 2012 (“PDPA”). This Notice will apply to the extent that there is any collection, use or disclosure of personal data in Singapore.
1.3 Any terms defined in the Privacy Statement have the same meaning when used in this Notice. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
1.4 If this Notice conflicts with the Privacy Statement, this Notice will prevail in respect of personal data collected, used or disclosed by us in Singapore provided always that if any provisions of any local law are more restrictive than the provisions of this Notice, the provisions of the more restrictive local law will apply.
2. Consent
By voluntarily providing any personal data in the course of interacting with us as described in the Privacy Statement, otherwise accessing or using the Offerings and/or submitting information to us via any forms or other data collection means or processes, you confirm that:
(a) you have read, understood and agreed to our collection, use, disclosure and/or retention of your personal data in the manner set forth in this Notice.
(b) you thereby consent to the collection, use and/or disclosure of such personal data by us for the purposes for which such personal data were disclosed and/or for any reasonable purposes for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise.
(c) where you give us personal data about other individuals, you are authorised to disclose and consent, on their behalf, to the use of such personal data for the purposes for which such personal data were disclosed and/or for any reasonable purposes for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise.
3. Reliance on Legitimate Interests Exception
3.1 In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Lovevery or another person. In relying on the legitimate interests exception of the PDPA, Lovevery will assess the likely adverse effects on you and determine that the legitimate interests outweigh any adverse effect.
3.2 In line with the legitimate interests exception, we may collect, use or disclose your personal data for the following purposes:
(a) Fraud detection and prevention.
(b) Detection and prevention of misuse of services.
(c) To help maintain the safety, security, and integrity of our site, products, services, databases, other technology assets, and business.
(d) To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or in connection with recalls and product safety matters.
3.3 The purposes listed in the above clause 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.
4. Withdrawing Your Consent
4.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed in the Privacy Statement by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
4.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
4.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing the Offerings to you or progress your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.
4.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
5. Access to and Correction of Personal Data
5.1 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.
5.2 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.
5.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) calendar days. Should we not be able to respond to your request within this time, we will inform you in writing within thirty (30) calendar 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).
5.4 Please note that depending on the request that is being made, we may not need to provide you with access to documents which contain your personal data, but only to access to the personal data contained in these documents. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that we have on record, if the record of your personal data forms a negligible part of the documents.
6. Protection of Personal Data
6.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we apply technical and organisational controls that we believe are reasonably appropriate to protect personal information, including the use of secure databases for personal data.
6.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
7. Retention of Personal Data
7.1 We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
7.2 We will cease to retain your personal 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 purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.
8. Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
9. Transfers of Personal Data outside of Singapore
As mentioned in the Privacy Statement, we may transfer, process, and store your personal data outside of Singapore, including in the United States. Where we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
10. Contacting our Data Protection Officer
10.1 You may contact us:
(a) if you have any enquiries or feedback on our personal data protection policies and procedures;
(b) to request to access and/or correct your personal data in our possession;
(c) to withdraw your consent to the continued use and/or disclosure of any personal data for all or any particular purpose; or
(d) if you have any questions or complaints regarding about how we are handling your personal data.
10.2 You may contact us by email to Lovevery’s designated Data Protection Officer at listening.au@lovevery.com or heretohelp@lovevery.com.
10.3 When contacting us, please state the purpose for which you are contacting us, your name and an email address at which we can contact you, and the nature of our relationship with you.
10.4 We will endeavour to respond to you as soon as possible within 10 business days. If we are unable to do so for any reason, we will inform you accordingly and the time by which we will respond to the request.
11. Changes to this Notice
11.1 This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
11.2 We may revise this Notice 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 Notice was last updated. Your continued access or use of the Offerings or employment and participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.
11.3 We recommend that you review this Notice from time to time so you are aware of any changes or updates to the Notice.
Effective date : February 27, 2024
Last updated : February 27, 2024
