Last updated and effective date: 11 June 2024

This Privacy Policy describes how SERICOPLUS PTE. LTD. (collectively and individually referred to as “SERI18,” “we,” “our,” or “us”) collects, uses, shares, and protects your Personal Data. It also explains the rights and choices you have with respect to your Personal Data, and how you can contact us for more information.

(1 ) What Our Privacy Policy Covers

This Privacy Policy covers the Personal Data that SERI18 obtains about you online. This includes when you visit, access, and/or use our website (“www.seri18.com”). It also applies when you communicate or interact with us, or participate in any of our promotions, programs, or events.

When we use the term “Personal Data,” we refer to all data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access, as well as any information for which the collection, disclosure, use, or processing is subject to data protection laws or regulations in any jurisdiction in which our Sites are made available by us. Our Sites may include links to third-party websites and/or applications. Please note that we have no control over the processing of Personal Data by websites or applications not owned by SERI18.

This Privacy Policy shall be governed in accordance with the laws of the Republic of Singapore.

(2 ) What We Collect

You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to transact with you or otherwise provide you with certain products and services. The following are examples of the various ways in which we may interact with you, and some of the types of Personal Data that we will/may collect, use, disclose and/or process in connection with that interaction. The column ‘Examples of Some of the Personal Data or Data Collected’ does not purport to exhaustively state the types of Personal Data that may be collected from you corresponding to the specified activity/interaction.

Examples of Some of the Personal Data or Data Collected

Browsing Activity and Website Usage

When you visit or use our Sites, we collect certain information about how you use and navigate our Sites, such as which links you click on, which pages or content you view, and other similar information or statistics. We also collect technical information about your device, operating systems, and web browser type.

Communications with us

When you communicate with us, including contacting us for support, to provide feedback or comments, to participate in a survey, or to make a request or other inquiry, we collect your name and contact information (such as e-mail address or phone number), as well as any other information that you choose to provide to us. 

Purchasing

When you make purchases through our website (“www.seri18.com”), we collect your personal and payment information to process and deliver your orders. This may include your name, contact information, shipping address, billing information, and purchase details. We may also use this information to communicate with you about your order, provide customer support.

Sweepstakes, Contests, and Promotions

When you participate in a sweepstake, contest, or other similar campaign or promotion, we may collect your name, contact information, and in some cases limited demographic information and content generated by participants. Some campaigns and promotions have a social networking component, and if you choose to submit additional information such as social media profiles and handles, photographs, and other content, we will collect such information as well.

(3) How We Collect, Use, Disclose Your Personal Data

We will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes: 

(a) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Sites. Without limiting the generality of the foregoing, if you:

(i) assessing and processing your request for the purchase of and/or subscription to our products and/or services;

(ii)  registering you as a customer of SERI18 and/or to deal with, process and/or administer the account that you may open with us, including to facilitate your transactions or activities on the Sites, or your transactions or activities with us;

(b) administering, facilitating, processing and/or dealing with your relationship with us, any transactions or activities carried out by you on the Sites. This includes processing your application, orders and payment transactions; implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a purchase to be delivered to a third party recipient, you consent to us disclosing Personal Data that identifies you, to the said third party recipient (such as but not limited to your name). Further, you acknowledge and agree that delivery of your purchase could involve disclosure of certain Personal Data about you to bring about delivery of the same such as your name and contact details, which may be disclosed on the cover of the parcel, on an envelope or a delivery related document, as the case may be, which could be seen by third parties who view such parcel, envelope or said document;

(c) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf including responding to your customer service enquiries and complaints; or responding to or dealing with your interactions with us;

(d) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the Sites, your membership program and/or account with us, your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(e) providing services to you as our account holder, as our customer, as a member of our membership program(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;

(f) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback” ) that you provide through Social Networking Sites, to the Sites, or to us (including in person), with other users of the Sites or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business of SERI18, and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public’s purchasing decision or for the public’s information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of SERI18’s marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Please do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately email our Customer Department at SERI18@bestech.com.sg and head the subject of your email with the word “Confidential”;

(g) Where you have provided your consent to us, whether such consent was obtained through the Sites, or otherwise, sharing your Personal Data with or disclosing your Personal Data to other users of the Site or with/to the public, through the Site or any other media (whether print, online, or otherwise) or communication platform as we so choose, at our discretion, such as but not limited to as part of SERI18’s marketing collaterals/materials or corporate video.

(h) carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations (in any Country/Region) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (in any Country/Region) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (in any Country/Region) or that may have been put in place by us or our affiliates/associated companies;

(i) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and/or investigating complaints;

(j) complying with or as required by any applicable law, court order, order of a regulatory body, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (in any Country/Region), with which we or our affiliates/associated companies are expected to comply;

(k) complying with or as required by any request or direction of any governmental authority (in any Country/Region) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (including but not limited to Singapore Customs and Ministry of Health) (in any Country/Region). For the avoidance of doubt, this means that we may/will disclose your Personal Data to such parties upon their request or direction; 

(l) conducting research (including customer research), surveys, market surveys, analysis and/or development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities, or to improve our understanding of your interests, concerns and preferences, in order to enhance any continued interaction between yourself and us connected or in relation to the Sites or improve any of our products or services. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face-to-face interview survey, by way of email or postal mail;

(m) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, anywhere in the world;

(n) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of SERI18 or that of its affiliates/related corporations;

(o) for marketing purposes where you have provided your consent to us for the same, and with such consent, we (and/or our related corporations and affiliates) may/would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, services and/or events (including products, services and/or events of third party organisations with which we may collaborate with), that we (and/or our related corporations and affiliates) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future;

(p) to implement and maintain our information technology systems, including to store and process Personal Data in computer databases and servers located anywhere in the world;

(q) anonymization of your Personal Data. In this regard, you acknowledge that Personal Data that has been anonymized is no longer Personal Data;

(r) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of SERI18 or of its affiliates/related corporations; and

(s) SERI18, reporting purposes including but not limited to reporting on SERI18’s business performance (the purposes set out above shall be collectively referred to as the “Purposes”)

(4) How We Share Your Personal Data

SERI18 may share and disclose your Personal Data to third parties anywhere in the world from time to time for one or more of the Purposes described in this Privacy Policy. In this regard, you agree and consent that we are permitted to disclose your Personal Data to such third parties anywhere in the world for one or more of the Purposes, and for such third parties to subsequently collect, use, disclose and/or process your Personal Data, for one or more of the Purposes. Without limiting the generality of the foregoing, SERI18 may share or disclose your Personal Data to the following third parties or in the following circumstances for one or more of the Purposes or other purposes stated herein:

(a) Corporate affiliates. We may share your Personal Data with our corporate affiliates, and subsidiaries anywhere in the world;

(b) Service Providers. We may share your Personal Data with third parties that perform services to support our core business functions and internal operations, including fulfilling orders, delivering packages, complying with your request for the shipment of products or the provision of services by a third party, sending postal mail and e-mails, analysing customer data, providing marketing assistance or carrying out marketing activities, administering our Ratings & Reviews, processing credit card and debit card payments, investigating fraudulent activity, conducting customer surveys and research, providing customer services, information technology service providers and data centre service providers including those who store and process Personal Data in computer databases and servers located anywhere in the world, and with any other third parties to whom disclosure by SERI18 is for one or more of the Purposes and such third parties would in turn be collecting and processing your Personal Data for one or more of the Purposes.

(c) Third Party Partners. We may share your Personal Data with third parties that we have partnered with to jointly create and offer a product, service or joint promotion. Such sharing by us will only be carried out if : 

• the purpose for such sharing falls within one of the Purposes above;
  
• an exception to the requirement of consent under applicable data protection law applies;
• such sharing has been notified to you in this Privacy Policy; or
• if we have obtained your consent for the same otherwise.

For example, if you decide to obtain a product or service that is offered by these third party partners, the Personal Data you provide will be shared with us and them. The third party partner’s use of your Personal Data is not governed by this Privacy Policy.

(d) Legal Process. We may disclose Personal Data as required by any applicable rules, law or regulation, regulatory policies, industry codes of practice or guidelines, judgements, court orders, orders, directions or requests issued by any court, legal or regulatory body in any jurisdiction applicable to us, or our corporate affiliates, including complying with disclosure requirements of any law binding on us or our corporate affiliates, and/or for the purposes of any guidelines issued by regulatory or other authorities (in any Country/Region), with which we or our corporate affiliates are expected to comply, government inquiries or investigations. We may also disclose Personal Data to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect, prevent and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.

(e) Business Transfers. We may share Personal Data with another company that buys some, or all, of the assets or stock of SERI18, and that company may use and disclose Personal Data for purposes similar to what is described in this Privacy Policy. SERI18 may also share Personal Data with prospective purchasers to evaluate the proposed transaction. You consent to the foregoing. For the avoidance of doubt, you acknowledge and consent to SERI18 sharing anonymised information such as but not limited to in the following circumstances:

• Aggregate information. We may share anonymised aggregate information about our customers with advertisers and marketing partners; and
• Behavioural-based advertising. A third party may use technology to collect anonymised information about your use of the Site so that they can provide advertising about products and services tailored to your interest. That advertising may appear either when you are using the Sites or using the Internet or your mobile device to visit other websites.

(5) Mobile Technology

In addition to the above, we may use the following technologies to automatically collect information about your activities on the Sites, as the case may be (each a “Mobile Technology”). Not all Mobile Technologies described below will collect Personal Data, however to the extent that any such Personal Data is collected, such Personal Data will be collected, used or disclosed for the purposes described below, or for one or more of the purposes described in this Privacy Policy.

How They Operate

Cookies

For users of the Site, please note that SERI18 may deposit “cookies” in your computer or your mobile device in order to identify you. Cookies are small data text files that are sent from a server computer during a browsing session. Cookies are typically stored on the computer’s hard drive and are used by web-sites to simulate a continuous connection to the site. By continuing to use the Site, you are agreeing to the use of cookies deposited by SERI18 in your computer or your mobile device. However, please note that we have no control over the cookies used by third parties. Security measures have been employed to prevent unauthorized access to visitor data. However, visitors acknowledge that SERI18 does not control the transmission of data over telecommunication facilities including the Internet. Therefore, to the extent permitted by applicable law, SERI18 will not be responsible for any breach of security or the unauthorized disclosure or use of any such data on the Internet, through no fault of SERI18. Not all cookies collect Personal Data and you may configure your browser to reject cookies. However, this may mean you may not be able to take full advantage of the services or features on the Site.

Web Beacons

Web beacons are small graphic images on a web page or in an e-mail that can be used for such things as recording the pages and advertisements clicked on by users, or tracking the performance of e-mail marketing campaigns.

Analytics Tags

We use analytical tags to analyse what our users/customers like to do and the effectiveness of our features and advertising. They can also help us customize your browsing and shopping experience. We may use information collected through analytical tags or tracked links in combination with your Personal Data. We may also combine Personal Data you provide to us with other Personal Data already within our possession (such as purchase history and demographic information). We often work with other companies such as, for example, AppsFlyer Ltd., to help us track, collect and analyse this information but they are prohibited from using this information for any other purpose.

Web Server Logs

Web server logs are records of activity created by the mobile device or computer that delivers the webpages you request to your browser. For example, a web server log may record the search term you entered or the link you clicked to bring you the webpage. The Web server log also may record information about your browser, such as your IP address and the cookies set on your browser by the server.

(6) How We Protect Your Personal Data

We realise that you trust us to protect your Personal Data. We take all reasonable steps to ensure your Personal Data is kept confidential and secure, and to take appropriate technical and organizational measures to prevent unlawful or accidental destruction, accidental loss, unauthorized collection, disclosure, use, copying, modification, leakage, loss, damage, alteration or access or other unlawful forms of processing. While we take all reasonable steps to keep your Personal Data in our possession confidential and secure, no method of transmission over the internet or security system is perfect, and we cannot promise that Personal Data about you will remain secure in all circumstances.

We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with.

We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.

(7) Children’s Privacy

We do not, and do not intend to, transact directly with anyone we know to be under the age of 18. By providing any Personal Data to us, you declare that you are over the age of 18. If you are under the age of 18, you should use the Site or otherwise transact with us only with the consent of a parent or guardian and should not submit any Personal Data to us.

(8) Communicating With Us

If you have any queries regarding our Privacy Policy, please contact us by email at SERI18@bestech.com.sg.

(9) Changes To This Policy

We may revise this Privacy Policy from time to time. We will notify you by posting an updated version of the Privacy Policy on the Site. We encourage you to check the Site and review this Privacy Policy regularly to stay informed of our personal data protection policies, and to stay informed of the methods you can use to control the use of your Personal Data and protect your privacy.

(10) General

Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to SERI18 with regard to processing of your Personal Data. For the avoidance of doubt, in the event that applicable law permits an organisation such as us to collect, use, disclose or process your Personal Data without your consent, such permission granted by the law shall continue to apply. Further, where applicable law provides us with rights in processing or handling your Personal Data, such rights shall prevail notwithstanding anything stated in this Privacy Policy.