Privacy Policy

Any personal information or material sent to Singapore Wine Vault’s (“SWV”) mobile app, website and/or submitted to SWV is subject to this Privacy Policy. You expressly agree that, in connection with our provisions of goods and/or services to you, your personal information may be transferred locally or across international borders to third party service provides and/or financial institutions, and to countries with different levels of data protection laws to the country from where you submitted your personal information.

1. Scope of this Privacy Policy
   This Privacy Policy explains how your personal data is collected, used and disclosed by SWV and/or its affiliated companies. It also tells you how can you access and update your personal data and make certain choices about how your personal data is used.

   This Privacy Policy covers both SWV’s online and offline data collection activities, including Personal Data that SWV collects through its various channels such as its website, mobile app, social networks, customer service officers, points of sales and events.

   SWV combines personal data that it collects via various methods and/or its affiliated entities.

2. Sources of Personal Data

   This Privacy Policy applies to personal data that SWV collects from or about you, through the methods described below (see clause 2), from the following sources:

   • The Singapore Wine Vault Website
   • The Singapore Wine Vault Mobile App available over IOS and Android
   • Email, text and other electronic messages between SWV and you.
   • Phone calls between a SWV Customer Service Officer and you
   • The SWV Storage Facility
   • Registration and/or similar forms that SWV collects via mail, demonstrations, contests and other promotion, or events.
   • Social networks, publicly available information.
3. Information SWV Collects About You And How It Collects Its:

   Depending on how you interact with SWV (online, offline, over the phone, etc), SWV collects various types of information from you. The information that may be collected from you is described below:

   Personal Contact Information: This includes any information you provide to SWV that would allow it to contact you, such as your name, postal address, email address, social network details and/or phone number.

   Account Login Information: Any information that is required to give you access to your specific account and profile. Examples include your login ID/email address, user name, password in unrecoverable form, and/or security question(s) and answer(s).

   Demographic Information: Any information that describes your demographic or behavioural characteristics. Examples include your date of birth, age or age range, gender, geographic location, favourite products, hobbies and interests and household or lifestyle information

   Technical Information About Your Computer and/or Mobile Device: Any information about the computer system or other technological device that you use to access SWV’s mobile app and/or website. Examples include the internet protocol address used to connect your computer to the internet, operating system type, and web browser type and version. If you access the SWV mobile app or website via a mobile device, the collected information will also include, where permitted, your mobile device’s unique device ID, advertising ID, geo-location, etc.

   Website and/or Communication Usage Information: As you use/navigate SWV’s mobile app and/or website, SWV collects certain information about your actions. This includes information such as which links you click on, which pages or content you view and for how long, and other similar information and statistics about your interactions, such as content response times, download errors and lengths of visits to certain pages. This information is captured automatically through the use of cookies and web beacons.

   Consumer Feedback: This includes information that you voluntarily share with SWV about your experience using its products, services, mobile app and/or website.

   Consumer Generated Content: This refers to any content that you create and then share with us on a social network or by uploading it onto SWV’s mobile app and/or website. Examples of such content includes photos, videos, writings and other similar media or content.

   Social Network Information: This refers to any information that you share publicly on a social network or information that is part of your profile on a third party social network that you allowed to be shared with SWV. Examples include your basic account information (eg. name, email address, gender, birthday, profile picture, etc) and any other additional information or activities that you permit the third party network to share. SWV receives such information every time you interact use a social networking feature that is integrated in SWV’s mobile app or website or every time you interact with SWV through a social network.

   Payment and Financial Information: This refers to any information that SWV needs in order to fulfil an order or service request made by you. Examples include your debit or credit card details or other forms of payment.

4. Uses Made of Your Personal Data
   The following paragraphs describe the various purposes for which SWV collects and uses your personal data and that different types of personal data that are collected for each purpose.

   Customer Service: SWV uses your personal data for customer service purposes, including responding to your inquiries. This typically requires the use of certain personal contact information and information regarding the reason for your inquiry. (eg. inventory list, delivery status, etc).

   Contests, Marketing and Other Promotions: SWV uses your personal data to provide you with information about goods and services. (eg. marketing communications, campaigns or promotions) This may be done via email, advertisement, phone call, text message and post.

   Social Networks: SWV uses your personal data when you interact with it via a third party social network (eg. liking it on facebook) to send you advertisements and/or engage you on the social network.

   
   

   Customer Personalisation:
   SWV uses your personal data to do the following:

   • Analyse your preference and habits and recommend specific products
   • To improve and personalise your experience on its mobile app and website.
   • To allow you to participate in interactive features (eg. remembering your username for future access, etc)
   • To show you specific content or promotions that are tailored to your interests

   Order Fulfilment: SWV uses your personal data to process and deliver your orders, inform you of the status of your orders, correct addresses and conduct identity verification and other fraud detection activities. This involves the use of certain personal information and payment information.

   Other General Purposes: In accordance with applicable laws, SWV uses your personal data for other general business purposes, such as conducting internal marketing and demographic studies and measuring the effectiveness of advertising campaigns.

   Legal Compulsion, Merger or Acquisition: In the event that SWV or its assets are acquired by, or merged with another company, SWV may share your personal data with any of its legal successors. SWV may also disclose your personal data to third parties in the following scenarios:

   • When required by applicable law
   • In response to legal proceedings
   • In response to a request for a competent law enforcement agency
   • To enforce the terms of any agreement or the terms of its mobile app and website
5. Disclosure of Your Personal Data

   5.1 In addition to its affiliated entities, SWV shares your information with the following third party organisations:

   Service Providers: These are external companies that SWV uses to help them run their business (eg. delivery fulfilment, payment processing, debt collection, mobile app and/or website development, etc). Service providers and their selected staff are only allowed to access and use your personal data on SWV’s behalf for the specific task(s) that they have been requested to carry out and are required to keep your personal data confidential and secure.Third Party Companies: Except in situations where you have given your consent, SWV does not license or sell your personal data to third party companies for its own marketing purposes. SWV will disclose your personal data to third parties for legal reasons or in the context of an acquisition or a merger (as provided in clause 3)

6. Retention of Your Personal Data
   6.1 In accordance with applicable laws, SWV will use your personal data for as long as necessary to satisfy the purposes for which your personal data was collected (as described in clause 3 above) or to comply with any applicable legal requirements.
7. Disclosure, Storage and/or Transfer of Your Personal Data
   7.1 SWV takes a variety of measures to keep your personal data confidential and secure. These measures do not apply to information that you choose to share publicly. (eg. through a social network)

   People Who Can Access Your Personal Data: Your personal data will be processed by SWV’s authorised staff, on a need to know basis, depending on the specific purpose for which your personal data was collected.

   Security Measures SWV Takes: SWV stores your personal data in operating environments that use reasonable security measures to prevent unauthorised access. SWV follows reasonable standards to protect personal data. While SWV is unable to guarantee the security of your personal data during transmission through its mobile app and/or website or during storage, SWV will do its best to protect such personal data.

   Security Measures You Are Expected To Take: When signing up for an account, please ensure that you choose an account password that will be difficult for others to guess and never reveal your password to anyone else. You are responsible for keeping your password confidential and for any use of your account. If you use a shared or public computer, never choose to have your login ID/email address or password remembered, and ensure that you log out of your account after such use.

   Transfer of Your Personal Data: The storage and/or processing of your personal data as described above may require that your personal data is ultimately transferred/transmitted to and/or stored at a destination outside of your country of residence. Where permitted by law, by accepting the terms of our privacy policy, you agree to such transfer/transmission, storage and/or processing. You also agree that such transfer/transmission may be to and/or storage/processing may take place in countries offering a lower level of protection than your country of residence.

8. Access to Your Personal Data

   Access to Personal Data: Where provided by law, you, your successors, representatives and/or proxies may access, review and request for a copy of the information held by SWV about you.You may do so by sending SWV an email to DPO@singaporewinevault.com or speaking with a SWV Customer Service Officer over the phone and providing SWV with proof of your identity. (Ie. Providing us with your personal details) If the request is submitted by a person other than you, the request must be accompanied by a letter authorising such person to access, review and request for a copy of your information duly executed by you.

9. Changes To Our Privacy Policy
   If SWV changes the way it handles your personal data, it will update this Privacy Policy. SWV reserves the right to make changes to its practices and to this Privacy Policy at any time. If SWV updates this Privacy Policy, it will post an updated version on its mobile app and website. In such an event, SWV will notify you of the updated Privacy Policy and how to access it.
10. Data Officer & Contact
    To ask questions or give SWV your comments on its Privacy Policy and/or its privacy practices or to make a complaint about SWV’s compliance with applicable privacy laws, you may contact SWV’s Data Officer (DPO) at DPO@singaporewinevault.com .SWV will acknowledge and investigate any complaint about the way it manages your privacy data.