Luminari Enterprise Pte Ltd (referred to hereinafter as the “Company”) recognizes its responsibilities in relation to the collection, holding, processing, use and/or transfer of personal data under the Personal Data Protection Act 2012 (“PDPA”). Your privacy is of utmost importance to us. This data protection statement (the “Statement”) outlines how we collect, use, store and disclose your personal data in accordance with the PDPA. Please take a moment to read about how we collect, use and/or disclose your personal data so that you know and understand the purposes for which we may collect, use and/or disclose your personal data. By accessing the Website, you agree and consent to the Company, its related corporations, business units and affiliates, as well as their respective representatives and/or agents (collectively referred to herein as “Luminari”, “us”, “we” or “our”), collecting, using, disclosing and sharing amongst themselves the personal data, and to disclosing such personal data to the relevant third party providers. This Statement supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your personal data. We may from time to time update this Statement to ensure that this Statement is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, the prevailing terms of this Statement shall apply. For the avoidance of doubt, this Statement forms part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions.

 

What is Personal Data

 

Personal data refers to any data or information about you from which you can be identified either (a) from that data or (b) from that data and other information to which we have or are likely to have access. Depending on your relationship with us (e.g. Prospective or current member, employee or business partner), the personal data about you that we may collect, use, store and disclose include: your contact details like your name, passport or other identification numbers, contact numbers, address, email; your personal details enabling us to evaluate and manage your member, employment or business relationship with us, e.g. your work experience, education, date of birth, bank details; your personal details enabling us to analyze your situation, determine suitable strategies and execute respective action, e.g. family status, financial status, transaction history; photos and videos of you from our events or office surveillances; and information about your use of our services and website, including cookies and IP address.

 

We Keep Your Personal Data Confidential and Secure

 

At each stage of data collection, use and disclosure, we implement physical, electronic, administrative and procedural safeguards to protect your personal data against loss, misuse, damage and unauthorized access, modifications or disclosures.

 

Purposes for Collection, Use and Disclosure of Your Personal Data

 

We collect, use and/or disclose your personal data to provide you with outdoor products and health solutions, which includes the use of the Luminari Enterprise platform to retail and provide services, including operations for these purposes. This may include the following (non-exhaustive) as applicable to the relationship we have with you:

 

evaluating your standing, resources and capabilities to enter or maintain a relationship with you as a member, user or other;

responding to your queries and requests and handling complaints;

internal reporting and analysis related to our business operations;

maintaining records of our interactions with you, through telephone recordings, documentation (hard copy and electronic), and any other purposes related to the above purposes.

 

If we wish to collect, use, retain and/or disclose your personal data for any other purposes, we will adequately seek your consent.

 

How We May Collect Your Personal Data

 

Generally, we may collect your personal data ourselves or through third parties in ways including the following :

 

during our preliminary discussions with you to establish a new member relationship, enter into warranty of products purchased or for any other business relationship;

when you interact with our employees;

when you communicate with us by email or telephone, your emails will be retained and we may monitor and/or record your voice calls to us;

when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;

when you access our website; when you respond to our requests for additional personal data;

or when you submit your personal data to us for any other reason.

 

When you access our website you generally do so anonymously. Your activity may however be monitored by Cookies or other navigational data. “Cookies” are small data files sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website. You are responsible for ensuring that the personal data you provide to us is accurate, complete, and not misleading and that such personal data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your personal data, please reach out to your Relationship Manager or our Data Protection Officer. Where you provide us personal data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.

 

Who We May Disclose Your Personal Data to

 

Generally, we shall protect and keep confidential your personal data. We will disclose your personal data only with your consent and for purposes that you have been informed about. However, subject to applicable laws, we may disclose your personal data for the purposes set out above to parties such as those described below:

 

banks, financial institutions, credit card companies and their respective service providers;

agents, contractors or third party service providers who provide services to us such as payment, data processing, storage and archival;

our professional advisers such as our auditors and lawyers; and regulators and authorities;

Luminari Enterprise Group of Companies.

 

When we disclose your personal data to third parties, we will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations, save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted. If your personal data has to be transferred overseas, we will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.

 

How Long We Keep Your Personal Data For

 

We shall store your personal data for as long as necessary to fulfill the purposes for which such data was collected, our business purposes, our internal and legal needs or as is otherwise legally required.

 

Queries, Access/Correction Requests and Withdrawal of Consent

 

If you :

 

have queries about our data protection processes and practices;

wish to request access to and/or make corrections to your personal data in our possession or under our control;

or wish to withdraw your consent to our collection, use or disclosure of your personal data;

 

Please submit a written request (with supporting documents, (if any) to our data Protection Officer at:  9 Yishun Industrial St 1 #01-79 S768163. Our DPO shall strive to respond to you within 30 days of your submission. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may not be in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

 

If you have a Complaint

 

We are committed to protecting your personal data. If, however, you should be dissatisfied with our handling of your personal data, please submit a written complaint containing details of your dissatisfaction to our DPO. Our DPO shall acknowledge in writing the receipt of your complaint within 2 business days. Within 10 business days, our DPO shall contact you to provide you with an estimated time frame for our investigations and resolution of your complaint. If your complaint requires more time beyond such estimation to resolve due to its complexity, our DPO shall inform you accordingly on or before the expiry of the original estimated time frame. In the event that the DPO’s investigations conclude with a solution that is unsatisfactory to you, you may wish to contact our Managing Director.  Our Managing Director will acknowledge your complaint within 2 business days and strive to provide a satisfactory solution to you within 10 business days. In the unlikely event that we cannot reach an agreement with you, you may wish to refer your complaint to the Personal Data Protection Commission or consider dispute resolution by way of mediation.